404(b)(1) ALTERNATIVES ANALYSIS

Transcription

1 404(b)(1) ALTERNATIVES ANALYSIS Submitted to BHP Billiton Canada, Inc. Saskatoon, Saskatchewan Canada 404(b)(1) Alternatives Analysis BHP No HS-RPT Revision 0 A June 2018

2 404(b)(1) Alternatives Analysis BHP No HS-RPT-55047, Revision 0 Hoquiam, Washington Submitted to Ms. Valerie Bond BHP Billiton Canada, Inc. 130 Third Avenue South Saskatoon, SK S7H 1L3 Canada 18 June 2018 Submitted by BergerABAM 210 East 13th Street, Suite 300 Vancouver, Washington A

3 404(B)(1) ALTERNATIVES ANALYSIS Hoquiam, Washington TABLE OF CONTENTS SECTION PAGE ACRONYMS AND ABBREVIATIONS... III INTRODUCTION Analysis Conclusion Summary... 1 ALTERNATIVES ANALYSIS PROCESS Section 404(b)(1) Background Analysis Process... 2 PURPOSE AND NEED Project Purpose/Water Dependency Project Need... 4 PHASE 1 GEOGRAPHIC AREA SELECTION Geographic Area Selection... 4 PHASE 2- POTENTIALLY PRACTICABLE ALTERNATIVES IDENTIFICATION Site Capacity Evaluation... 7 Potential Practicable Alternatives Screening Results... 8 PHASE 3- PRACTICABILITY EVALUATION Alternative A Grays Harbor Terminal Alternative B: Port of Tacoma SSA/MVV Site...13 Alternative B: General Site Conditions Alternative C: Port of Longview Barlow Point Site...16 Alternative C: General Site Conditions Alternative D: No Federal Action Alternative...18 General Site Conditions...18 PHASE 3- ALTERNATIVES PRACTICABILITY ANALYSIS Practicability Analysis Results Summary...19 PHASE 4: ENVIRONMENTAL ANALYSIS Existing Wetland Conditions Wetlands Impacts...21 Permanent Direct Wetland Impacts...21 Permanent Indirect Wetland Impacts...21 Temporary Wetland Impacts...21 Wetland Buffer Impacts Mitigation...25 PHASE 5: LEDPA IDENTIFICATION...25 BIBLIOGRAPHY...25 Hoquiam, Washington Page ii of iii

4 LIST OF TABLES Table 1. Alternatives Analysis Framework for Compliance with 40 CFR Table 2. Capacity Screening Results for Selected Alternatives... 8 Table 3. Practicability Considerations Summary Table 4. Wetland and Wetland Buffer Impacts LIST OF FIGURES Figure 1. Vicinity Map... 6 Figure 2. Alternative A. Grays Harbor Terminal Figure 3. Alternative B, Port of Tacoma, Stevedoring Services of America (SSA), Marine View Ventures (MVV) Site Figure 4. Alternative C, Port of Longview, Barlow Point ACRONYMS AND ABBREVIATIONS BHP BNSF CFR City CWA FAA Guidelines JARPA LEDPA MLLW MTPA MVV NWI Port PSAP SSA UPRR USACE BHP Billiton Canada, Inc. Burlington Northern Railroad Code of Federal Regulations City of Hoquiam Clear Water Act Federal Aviation Administration Section 404(b)(1) Guidelines Joint Aquatic Resources Permit Application least environmentally damaging practicable alternative mean lower low water million tonnes per annum Marine View Ventures National Wetland Inventory Port of Grays Harbor Puget Sound and Pacific Railroad Stevedoring Services of America Union Pacific Railroad U.S. Army Corps of Engineers Hoquiam, Washington Page iii of iii

5 404(B)(1) ALTERNATIVES ANALYSIS PROPOSED GRAYS HARBOR POTASH EXPORT FACILITY HOQUIAM, WASHINGTON INTRODUCTION BHP Billiton Canada, Inc. (BHP) is developing the Jansen potash mine in the Saskatchewan basin in Saskatchewan, Canada, to produce potash for export to overseas markets. Mine shaft development, initial surface works, and environmental studies are currently in progress. This report summarizes the process and results of the alternatives analysis BHP used to identify an export site that meets the project purpose (BHP 2016). 1 The objective of the project is to establish an outbound logistics strategy that will provide reliable access to markets in key geographies, along with competitive development and operating costs. A key part of this strategy is to develop a marine terminal for export of potash transported by rail from the Jansen mine to international markets in the Pacific Rim. The BHP analysis was extensive. Their analysis is summarized herein to address the framework of the United States Clean Water Act Section 404(b)(1) Alternatives Analysis guidelines relative to availability, cost, logistics, and existing technology and to identify the least environmentally damaging practicable alternative (LEDPA). 1.1 Analysis Conclusion Summary The alternatives analysis shows that the Grays Harbor Terminal 3 site (Alternative A) is the only practicable alternative for a potash export terminal in the United States that meets the project purpose and need and the associated capacity. There are adverse environmental impacts associated with site development that can be avoided, minimized, or mitigated, and therefore are not considered significant. This option is the LEDPA and is the preferred alternative. ALTERNATIVES ANALYSIS PROCESS 2.1 Section 404(b)(1) Background Section 404 of the CWA authorizes the U.S. Army Corps of Engineers (USACE) to issue permits for the discharge of dredged or fill materials into waters of the United 1 In 2010, Canadian Pacific Railway (CP), BNSF Railway Company (BNSF), and the Port of Vancouver, Washington (PoV) were selected to service Jansen s potash export-distribution requirements. Commercial agreements negotiations to provide this service progressed for four years, at which point BHP decided to let its existing agreements for rail and port service lapse due to a lack of confidence in the reliability of the rail solution. BHP subsequently initiated the screening process described below in 2014 to identify the optimal outbound logistics strategy and location for potash export. Hoquiam, Washington Page 1 of 26

6 States, including wetlands (33 U.S. Code 1344). Waters of the United States include coastal and inland waters, lakes, rivers, and streams, including adjacent wetlands and tributaries. The Section 404(b)(1) Guidelines (Guidelines) (40 Code of Federal Regulations [CFR] 230) are the substantive environmental criteria used by the USACE to evaluate permit applications. The Guidelines prohibit discharges of dredged or fill material into waters of the United States if a practicable alternative to the proposed discharge exists that would have less adverse impacts on the aquatic ecosystem, including wetlands, as long as the alternative does not have other significant adverse environmental impacts (40 CFR 230[a]). This analysis is triggered by the need for dredging in waters of the United States and impacts to wetlands to develop the Terminal 3 site. The analysis process is shown schematically on Table 1. The first part of the analysis is to identify alternatives and then determine whether those alternatives are practicable. An alternative is considered practicable if the site is available and the project is capable of being implemented after considering cost, existing technology, and logistics in light of overall project purpose (40 CFR 230[a][2]) (the identified practicable alternative(s) are then evaluated relative to project-specific criteria to identify the alternative that is the LEDPA (40 CFR Part [d]). The guidelines for project compliance with 40 CFR are set forth in an alternatives analysis framework as discussed below. 2.2 Analysis Process This summary is organized in accordance with the process described in the USACE Alternatives Analysis Framework (April, ), as shown on Table 1. The framework establishes five phases of evaluation to identify the LEDPA. The five phases include the following. Phase 1: Need, Purpose, and Geographic Area Phase 2: Alternatives Identification Phase 3: Practicability Evaluation Phase 4: Environmental Analysis Phase 5: LEDPA Identification 2 %20( ).pdf?ver= Hoquiam, Washington Page 2 of 26

7 Table 1. Alternatives Analysis Framework for Compliance with 40 CFR Hoquiam, Washington Page 3 of 26

8 PURPOSE AND NEED 3.1 Project Purpose/Water Dependency The purpose of the proposed project is to provide a rail-to-vessel export terminal that will allow the cost-effective transport of potash from the proposed Jansen Mine in Saskatchewan, Canada, to international markets in the Pacific Rim. This project purpose requires a marine terminal for berthing and loading oceangoing export vessels and is therefore a water-dependent activity. The overall project purpose is to establish an outbound logistics solution that provides reliable access to markets in key geographies, along with competitive development and operating costs, as BHP continues to develop the Jansen mine and associated potash export business. 3.2 Project Need The need for the project is the anticipated future demand for potash in emerging Pacific Rim markets where economic growth is driving increased agricultural production. PHASE 1 GEOGRAPHIC AREA SELECTION 4.1 Geographic Area Selection The initial geographic range considered for locating an export terminal consisted of the Great Lakes region, the Canadian and U.S. East Coast, the U.S. Gulf Coast, the U.S. Pacific Southwest Coast, the U.S. Pacific Northwest, and the Western Canadian Lower Mainland. BHP considered the following factors to determine the appropriate geographic area for the proposed export facility. Access to a navigation channel with a minimum draft of 12 meters (38 feet). Rail distance from the Jansen mine Maximum 2,250 miles. Access to Pacific Rim markets BHP is targeting Pacific Rim markets as the area anticipated to have the most future potash demand. Availability of sites of size suitable for efficient operation The site size needs to accommodate train unloading facility and rail loop for 8,500-foot trains, storage capacity and associated support buildings. Bulk facility focus of the port area A bulk-focused Port is assumed to have the necessary infrastructure for bulk materials handling (as opposed to containerfocused Ports). Seasonal restrictions Seasonal conditions such as icing of the navigation channel can delay vessel schedules and increase operations costs due to icebreaking requirements. Hoquiam, Washington Page 4 of 26

9 Operating costs Operating costs should be minimized by having appropriate site size and conditions, competitive rail service and other factors. The geographic screening narrowed the sites for evaluation to those located along the U.S. and Canadian Pacific coast because that area generally meets the screening criteria. PHASE 2- POTENTIALLY PRACTICABLE ALTERNATIVES IDENTIFICATION In the United States, four sites at three ports (see Figure 1) were identified for further analysis to select potentially practicable alternatives. The four sites include the following. 1. Port of Grays Harbor Terminal 3 2. Port of Tacoma SSA/MVV 3. Port of Longview Barlow Point 4. Port of Longview Berth 2 Hoquiam, Washington Page 5 of 26

10 Figure 1. Vicinity Map Hoquiam, Washington Page 6 of 26

11 5.1 Site Capacity Evaluation The four sites were further screened based on the ability of the site to meet the desired potash export capacity of 8 million tonnes per annum (mtpa). The criteria were defined as follows. 1. Site Capacity: The site is large enough to accommodate required operations and structures to meet the design potash throughput of 8 mtpa. The site needs to be large enough to accommodate an 8,500-foot-long rail loop and infrastructure required for a bulk handling facility including a product storage building with reclaimer and conveyance units, a rail car unloading facility, administrative services buildings, and conveyance to and from the shiploader and rail car unloading facility. Potash is transferred from the rail unloading facility to the storage building by conveyors. The storage building height is defined by providing clearance for the conveyors and mechanical equipment. The angle of repose of potash and the interior crane rail gauge defines the pile height, which in turn defines the height of the portal reclaimer. Adequate clearance must be maintained between the travelling portal reclaimer and the stacking conveyor gallery overhead. Additional height is required for structural members for the conveyor gallery and building structure. The assumed building dimensions are generally approximately 245 feet wide, approximately 160 feet high and approximately 1,100 feet long. The building will be supported by a steel and timber pile foundation. By choosing one terminal which is large enough for this infrastructure BHP will only be required to disturb a single area which will support its long term operations. 2. Rail Capacity: The site can accommodate an 8,500-foot-long rail loop BHP s trains will be approximately 8,500 feet long and will consist of 177 potash covered-hopper rail cars with three to five locomotives. The site will need to accommodate this length of train in order to avoid breaking trains into smaller units, using ladder tracks, or having the tail end of the train hang off of the property while rail cars are unloading. This will lead to a safer operation for both port terminal employees and the surrounding community and decreased operational noise (as shunting rail cars will not be required). Operating in this manner is more efficient due to decreasing the length of time required to unload a train and frequency of receiving trains. 3. Waterway Capacity: The site can access a navigable waterway with a minimum depth of 12 meters (38 feet). BHP has a strong preference to utilize a navigable waterway with a minimum depth of 38 feet in order to serve the required vessel size. The vessels used by BHP are Hoquiam, Washington Page 7 of 26

12 chosen based on the size of vessels which the customers receiving ports can currently accommodate and projections of the vessel sizes which will be required in the future. This ensures BHP will not be required to construct a new port as customers ports move to using larger vessels. Potential Practicable Alternatives Screening Results The capacity criteria screening results are summarized in Table 2. The screening resulted in elimination of the Longview Berth 2 site. The site does not meet the screening criteria for site capacity and rail capacity. The site is not big enough to accommodate rail and all associated buildings required to support the handling, storage and buildings needed for associated facilities. The rail loop would be located off site and would require breaking of unit trains and off-site rail car storage and staging. These conditions would impact the efficiency of site operations and would prohibit BHP s capacity goal of 8 mtpa of potash throughput for export. The remaining three sites (Port of Grays Harbor Terminal 3, Port of Tacoma SSA/MVV site and the Port of Longview Barlow point were identified as potentially practicable and were carried forth for more detailed screening. Table 2. Capacity Screening Results for Selected Alternatives Site Site Layout and Operations Rail Layout and Operations Waterway Capacity Terminal 3 Grays Harbor, WA Preliminary site layout indicates ability to meet design throughput capacity Can fit a whole unit train on site Loop can handle unit trains without breaking. Meets specified waterway draft. SSA/MVV Site Tacoma, WA Barlow Point Longview, WA Berth 2 Longview, WA Preliminary site layout indicates ability to meet design throughput capacity. Preliminary site layout indicates ability to meet design throughput capacity Ability to meet the design throughput capacity may be limited due to site size and rail inefficiencies Can fit a whole unit train on site Loop can handle unit trains without breaking; Queued trains have interaction with other terminals. Can fit a whole unit train on site Loop can handle unit trains without breaking. Cannot fit a whole unit train on site Rail loop cannot handle unit trains without breaking; Queued trains have interaction with other terminals Notes: Green indicates highly desired qualities present. Yellow indicates a balance of desired and undesired qualities. Red indicates undesired qualities present that eliminate the alternative from further analysis. Meets specified waterway draft. Meets specified waterway draft Meets specified waterway draft. Hoquiam, Washington Page 8 of 26

13 PHASE 3- PRACTICABILITY EVALUATION The three potentially practicable sites identified in Phase 2 are identified as Alternatives A, B and C. Alternative D is the mandatory No Action alternative that must be considered in accordance with the process requirements. The final step in identifying practicable alternatives consisted of evaluating conditions for Alternatives A though D relative to Availability Zoning Berth characteristics/constructability The availability of two class 1 rail carriers Other considerations that could impact terminal development this includes special restrictions or site conditions that could complicate site development or operations. Site conditions for the three potentially practicable sites and the no action alternative are described below with respect to these criteria. 6.1 Alternative A Grays Harbor Terminal 3 The existing Terminal 3 facility and adjacent parcels are located on the northern shoreline of the Chehalis River in Hoquiam, Washington. The site consists of approximately 200 acres located on the southeast corner of State Route 109/West Emerson Avenue and Paulson Road in the city of Hoquiam, in Township 17 North, Section 10, and Range 9 West north of the Willamette Meridian 3. The preliminary conceptual layout used in this analysis is shown in Figure 2. The Port s Terminal 3 site and adjacent parcels were originally a historical tideflat that was filled during the early twentieth century with dredged material from the Chehalis River and Grays Harbor. The northeast corner of the site was developed and used as a machinery manufacturing facility for pulp and paper equipment from 1971 through The central and west areas of the site were historically used as a log yard and log export facility by Rayonier Grays Harbor from 1981 through The Port purchased the site from Rayonier in The southeast upland portion of the site and the existing Terminal 3 dock are currently used by Willis Industries, a wood chip facility. The City parcel on the southwest upland corner of the site is occupied by the City s former wastewater 3 The project site is located on portions of tax parcels ( , , , , , , , , , , , , , , , , , , , and ) located in portions of Sections 3 and 10, Township 17 North, Range 10 West of the Willamette Meridian. Hoquiam, Washington Page 9 of 26

14 lagoon. The City is currently filling the lagoon with dredged material from the Chehalis River and Grays Harbor, landslide materials, and excess soil from other local projects. The northeast upland corner of the site (also known as the Lamb property) is occupied by a whiskey distillery. The remaining upland areas within the site have been cleared of vegetation in the past and are unused or undeveloped. Approximately 47 acres of wetlands, not including buffer areas, are present on the northern and eastern portion of the site. Hoquiam, Washington Page 10 of 26

15 Figure 2. Alternative A. Grays Harbor Terminal 3 Hoquiam, Washington Page 11 of 26

16 Site Availability The site consists of multiple parcels owned by the Port of Grays Harbor, the City of Hoquiam, and private landowners, totaling approximately 200 acres. The site is considered available for lease on commercially reasonable terms Zoning and other Permitting Requirements The City s zoning for the site is Industrial, the Comprehensive Plan designation is Industrial District, and Shoreline Master Program designation is High Intensity. The proposed uses are generally consistent with these designations. A variance for the height of some facilities would be required, but the project proposal is expected to satisfy City requirements for such a variance. Structure height at the site is also restricted by Federal Aviation Administration (FAA) regulated airspace conditions associated with the adjacent Bowerman Airport. It should be noted that the initial concept for the site layout during the alternatives analysis placed the storage building in the center of the site oriented in a north/south direction on the long axis to provide maximum avoidance of on-site wetlands. The initial concept was later modified (as shown on Figure 3) to relocate the storage building along the northern border oriented in an east/west direction along the long axis of the building. This reconfiguration is needed to comply with FAA requirements related to flight paths for aircraft approaching the adjacent Bowerman Airport. Development of the facility at this site would require a variety of other federal, state and local permits and approvals. The project is expected to satisfy the requirements to obtain those permits Size The approximately 200-acre site is sufficiently sized for construction of the necessary project infrastructure, including the rail loop, upland facilities, and marine terminal (Figure 3). All rail activities can be conducted within the site boundaries Deep-water Berth/Channel Access and Constructability The site has access to the Grays Harbor Federal Navigation Channel with a minimum depth of 12 meters. Construction of a new shiploading structure can be accommodated at the in-water portion of the site. The structures can be built with existing technology using typical pile-supported construction methods. Dredging approximately 110,000 cubic yards will be required to expand the existing berth to achieve the required berth depth Rail Carrier Conditions Two Class 1 railroads, BNSF Railway and the Union Pacific Railroad (UPRR), provide service to Centralia, Washington, located approximately 60 miles from the site. The Puget Sound and Pacific Railroad (PSAP) is the short line carrier that Hoquiam, Washington Page 12 of 26

17 transports trains from those carriers to the Port of Grays Harbor. The PSAP traverses the northern boundary of the site and a new spur would be constructed to extend the rail onto the project site. Short line rail track upgrades have been identified to alleviate congestion and improve safety off-site at-grade crossing along the short-line rail corridor in Aberdeen and Hoquiam. Various studies have been completed by local agencies to assess potential solutions, including grade separations. These issues are expected to be addressed in the future by the local agencies. The increase in rail activity is generally considered to be one train per day and will not significantly increase congestion at the existing crossings. 6.2 Alternative B: Port of Tacoma SSA/MVV Site Alternative B: General Site Conditions Alternative B is the SSA/ MVV site located on the Blair-Hylebos Peninsula in the Port of Tacoma, Washington. The site is located within an industrial area on the shores of Commencement Bay in Puget Sound on the east side of the Blair Waterway (Figure 3). The site has historically been an active industrial area. The site consists of four parcels 4 : one owned by SSA, one owned by the Port (Wypenn), and two held in trust for the Puyallup Tribe of Indians (the Blair Backup and the Blair Waterway properties). The City of Tacoma identifies eight wetlands across all four properties on the project site totaling approximately 16.8 acres, not including buffer areas. Roughly 2,500 feet of drainages traverse the site Site Availability The site is comprises parcels owned by the Port, SSA, and two parcels held in trust by the Tribe. BHP s analysis of commercial risk revealed significant contract challenges for BHP related to securing agreements. This site was therefore considered unavailable Zoning and other Permitting Requirements The City of Tacoma s zoning for the site is Port Maritime and Industrial, and the proposed uses are consistent with these designations. Development of the facility at this site would require a variety of other federal and state permits. The project is expected to satisfy the requirements to obtain those permits. 4 The Port of Tacoma SSA/MVV site is located on portions of Tax Parcels (Blair Backup), (SSA), (Blair Waterway Tribe), and (Wypenn). Hoquiam, Washington Page 13 of 26

18 Size This site consists of approximately 175 acres. It is large enough and of a shape that would accommodate the required rail loop Deep-water Berth/Channel Access and Constructability The site is located on the east side of the Blair Waterway and has direct access to the Blair Waterway Navigation Channel which has a minimum draft of 51 feet. Dredging would be required to lengthen the berth along the east shoreline to accommodate the design vessel sizes Rail Carrier Conditions The site could be potentially served by two Class 1 railroads (BNSF and UPRR) with Tacoma Rail providing short line service. Rail would need to be extended along Alexander Avenue to access the site and would pass through other terminals. The last half mile of rail access for both rail carriers could not be confirmed due to BNSF control of a portion of the rail, and there is a risk that two competitive Class 1 rail carriers would not be able to service the site. Competitive access for two rail carriers is a primary consideration in obtaining the best possible rail rates and is an important factor in site selection. Hoquiam, Washington Page 14 of 26

19 Figure 3. Alternative B, Port of Tacoma, Stevedoring Services of America (SSA), Marine View Ventures (MVV) Site 404(b)(1) Alternatives Analysis 8 June 2018 Hoquiam, Washington Page 15 of 26

20 6.3 Alternative C: Port of Longview Barlow Point Site Alternative C: General Site Conditions The Barlow Point site is located within an industrial corridor along the Columbia River in the southwestern portion of the city of Longview in Cowlitz County, Washington. The site consists of four parcels 5 located on the north shoreline of the Columbia River (Figure 4). The Port of Longview purchased the 275 acre Barlow Point properties in October 2010 at a trustee sale. The site was previously owned by Terra Firma, Inc. and was the site of Longview Motocross. Historical uses of the site generally consisted of agricultural activities, such as farming and grazing. Portions of the site were used as a motocross racetrack and sand drag strip in recent years. Since purchasing the land, the Port has contracted with a farmer to plant and harvest hay on approximately 80 acres of the site. The Barlow Point site is located on an historic floodplain of the Columbia River. National Wetland Inventory (NWI) mapping for the Barlow Point site identifies portions of six wetland polygons on the Barlow Point site, and five of these wetlands extend onto portions of the proposed site. According to the NWI map, approximately 45 acres of wetland overlap the project site Site Availability The Alternative C site consists of 275 acres of privately owned property that is generally available for sale or lease. There is an existing legal conflict regarding ownership of the waterfront portion of that property and could limit availability. Waterfront access is critical because there must be access for the shiploader and berth construction and during operations. A legal dispute could result in schedule and budget delays, and there is some risk that an agreement could not be reached Zoning and other Permitting Requirements The site does not have zoning or permitting issues that would pose a risk to the project Size This site consists of approximately 275 acres. It is large enough and of a shape that would accommodate the required rail loop. 5 The project site is located on portions of Tax Parcels , , , and (b)(1) Alternatives Analysis 8 June 2018 Hoquiam, Washington Page 16 of 26

21 Figure 4. Alternative C, Port of Longview, Barlow Point 404(b)(1) Alternatives Analysis 8 June 2018 Hoquiam, Washington Page 17 of 26

22 Deep-water Berth/Channel Access and Constructability The site is located on the north shoreline of the Columbia River and is adjacent to the Columbia River Federal Navigation Channel. There are no existing deep-draft berths at the site, and dredging of intertidal and shallow intertidal habitat would be required to provide adequate draft for the vessel berth. A channel would need to be dredged from the new vessel berth to the navigation channel. The navigation channel passes within about 600 feet of the shoreline at the closest point. For the purposes of this discussion, the permitting, construction, and schedule associated with dredging at this site are feasible. However, the volume and cost of dredging and the impacts to intertidal habitats are likely to be significantly higher with this alternative due to the longer distance from the shoreline to the navigation channel and the lack of previous dredging in that area Rail Carrier Conditions The site can accommodate the rail loop and facility as shown on Figure 4. Both the UPRR and BNSF lines approach the site; however, BHP was unable to confirm that both lines would be able to access the last half mile to the project site. BHP would be completely reliant, with little potential influence, on third-party processes to ensure competitive access is available in the last mile. Competitive access for two rail carriers is a primary consideration in obtaining the best possible rail rates and is an important factor in site selection. 6.4 Alternative D: No Federal Action Alternative General Site Conditions Alternative E is the No Federal Action Alternative; there is no site to evaluate relative to the project-specific practicability criteria. PHASE 3- ALTERNATIVES PRACTICABILITY ANALYSIS BHP completed a due diligence process of the alternatives to further evaluate potential practicability. That analysis was used to assess the alternatives relative to the 404 (b)(1) guidelines criteria (Availability, Cost, Logistics, and Existing Technology). A fifth category for Other Considerations was included to capture other site-specific factors that could affect practicability. Cost, existing technology, marine logistics (waterway access and draft), and the availability of two competitive rail carriers meet the project criteria for all the alternatives. These criteria are, therefore, not discussed further in this analysis. The results of the practicability analysis are summarized in Table 3. Hoquiam, Washington Page 18 of 26

23 Table 3. Practicability Considerations Summary Other Alternative Availability Logistics - Rail Considerations Alternative A The site is considered Terminal 3 available Grays Harbor, WA Supportive community Alternative B PTT Tacoma, WA Alternative C Barlow Point Longview, WA Alternative D No Action Notes: BHP's analysis of commercial risk revealed significant contract challenges for BHP related to securing agreements. BHP's analysis of commercial risk revealed significant legal issues associated with waterfront portion of the site that would complicate access to the water and site availability. Off-site rail upgrades are needed at existing at-grade rail crossings in Aberdeen and Hoquiam due to traffic congestion and safety concerns. Complicated last mile route to avoid container yards. Additional final access rail would need to be constructed. Potential access issue for competitive rail carriers. Risk associated with competitive rail access. Risk due to reliance on third-party processes to extend and control the rail line from the Class 1 corridor to the site. NA NA NA The adjacent Wildlife Refuge is an International Union for Conservation of Nature (IUCN) Protected Area; environmental impacts to the refuge must be avoided. The dredging volume, costs and intertidal impacts are likely to be higher for this alternative than the others due to the lack of previous dredging at the site and the distance from the navigation channel. Green indicates highly desired qualities present. Yellow indicates a balance of desired and undesired qualities. Red indicates undesired qualities present that eliminate the alternative from further analysis Practicability Practicable Not Practicable Not Practicable Not Practicable 7.1 Practicability Analysis Results Summary The results of the practicability analysis of the three site alternatives resulted in eliminating Alternative B and Alternative C based on the factors summarized in Hoquiam, Washington Page 19 of 26

24 Table 3. The practicability analysis identified Alternative A, Grays Harbor Terminal 3 as the only practicable alternative for the proposed export terminal site. PHASE 4: ENVIRONMENTAL ANALYSIS Phase 4 of the Alternatives Analysis is to (1) compare impacts to waters of the United States across all practicable alternatives and (2) determine if the practicable alternatives cause other significant effects. The practicability analysis identified Alternative A, Grays Harbor Terminal 3 as the only practicable alternative so a comparison of the environmental impacts of the practical alternatives is not possible. This section describes the environmental impacts of Alternative A in detail and describes how those impacts would be addressed. Environmental impacts associated with the development include the following. Wetland and buffer impacts due to site development Aquatic impacts from dredging a new berth and construction of the shiploader structures The potential impacts from developing Alternative A have been avoided and minimized to the extent practicable, and would not result in significant adverse effects to any aspect of the environment. Appropriate mitigation will be provided to compensate for unavoidable impacts to wetlands and the aquatic environment. The environmental impacts related to Alternative A are discussed below. 8.1 Existing Wetland Conditions Wetland delineations were initially performed by BergerABAM biologists in July 2017 and finalized in April The delineation revealed that there are three jurisdictional wetlands identified within the study area (Wetlands A, B, and C). These include two Category III depressional freshwater wetlands and a Category II tidally influenced estuarine wetland. Wetland A is an approximately 61.9-acre, Category III, palustrine forested wetland that covers the western portion of the study area. Approximately 37.2 acres of Wetland A is located on the study area, and approximately 24.7 acres extend off the study area to the east. Wetland B is an approximately 4.89-acre, Category III, palustrine emergent and palustrine forested wetland located in the northwest corner of the study area. Wetland B is a remnant area that has been developed upon fill material and that appears to be maintained by a combination of areas of high groundwater and slowly permeable soils. Vegetative species in Wetland B include a variety of native emergent, shrub, and tree species. Hoquiam, Washington Page 20 of 26

25 Wetland C is an approximately 0.39-acre, estuarine, Category II, tidal wetland located in the northwestern corner of the study site. This wetland consists of two excavated ditches that are located along the southern fill slope of the Puget Sound and Pacific Railroad rail line (along the northern boundary of the study area) and along the eastern fill slope of Paulson Road (along the northwestern boundary of the study area). These two ditches have a surface water connection with the waters of Grays Harbor off site to the west and are tidally influenced. The two ditches that comprise Wetland C are also hydrologically connected with Wetland B, but the excavated and channelized nature of Wetland C limits the tidal influence to the boundaries of Wetland C. 8.2 Wetlands Impacts Permanent Direct Wetland Impacts While wetland impacts have been avoided and minimized to the extent practicable (as discussed above) the project will result in unavoidable permanent direct impacts (fill) to on-site wetlands. These include impacts associated with the construction of portions of the rail loop, railcar unloading facility, product storage building, conveyors, and stormwater treatment and conveyance facilities. Permanent Indirect Wetland Impacts The project will also result in indirect impacts to wetlands, which will result from further fragmentation of the existing wetland network at the site, and the associated reduction in buffer for those wetland areas that have been avoided by the project. While indirect wetland impacts will not result in a net loss of wetland acreage, they have the potential to reduce wetland function. Temporary Wetland Impacts The project itself would not result in any temporary wetland impacts. However, some direct temporary wetland impacts could potentially occur associated with the construction of compensatory mitigation for the project. A compensatory mitigation plan is currently being designed for the project. Existing wetlands at the selected compensatory mitigation site may require grading and/or recontouring to establish the finished grades within the mitigation site. Existing vegetation, both native and invasive, would be removed during this process, and soils would be temporarily disturbed. These areas would be planted with native vegetation consistent with the mitigation plan and would be restored to a more highly functioning wetland condition. The minor temporary loss of wetland function would be offset by these proposed enhancements. Wetland Buffer Impacts The City s SMP (Appendix 2 Section ) establishes protective buffers for all regulated activities conducted adjacent to regulated wetlands. Base buffer widths are established based on the total point score from the wetland rating form, and the intensity of the proposed land use. Because the proposed project represents a high- Hoquiam, Washington Page 21 of 26

26 intensity land use, wetlands A, B, and C all have a 150-foot base buffer width. Ditches are exempt from regulation as wetlands under the SMP, and as such they do not have a regulatory buffer. Base buffer widths only apply to functioning buffers. Section B of Appendix 2 of the SMP clarifies that protective buffers do not include those areas functionally and effectively disconnected from the wetland, such as by a road or other structures. Most of the upland portion of the project site is a developed industrial site consisting of paved and/or compacted fill surfaces and/or roadways. Therefore, the functional portion of the buffers extend only from the wetland boundary to the toe of the existing fill or development that establishes the upland portion of site. Table 4 summarizes the wetland and wetland buffer impacts that would occur from the project. Table 4. Wetland and Wetland Buffer Impacts Impact Type Identifier Wetland Rating Impact (acres) Permanent/Direct Permanent Indirect Wetland A III Wetland B III 2.06 Wetland C II 0.12 Ditches N/A 2.91 Wetland A III Wetland B III 1.72 Wetland C II 0.04 Ditches N/A 0.15 Permanent Wetland Impacts (Direct and Indirect) Wetland Buffer Impacts Shoreline Buffer Impacts The City s SMP also establishes protective buffers along shorelines to retain areas of native vegetation and to allow habitat connectivity. The buffer for Type S waters of the state (including Grays Harbor) are established in Table 4-1 of the revised SMP, which establishes buffers by shoreline environmental designation and the water dependency of a proposed land use. A functional shoreline buffer is present in the northwestern corner of the site, adjacent to the tidal portion of Wetland C. This buffer extends into the site to the south and east a maximum distance of 150 feet. Impacts to approximately 3.53 acres of shoreline buffer will result from the construction of rail improvements Aquatic Impacts Impacts to aquatic habitats will occur from the construction of the new dock and ship loader, and from the dredging for the new berth. Hoquiam, Washington Page 22 of 26

27 The project will result in a total of approximately 48,114 square feet of new solid overwater coverage associated with the construction of the new shiploader. The shiploader has been designed such that the majority of this structure is located in deep water habitats, to minimize impacts to intertidal habitats where the effects of overwater shading can be more pronounced. Overwater coverage in intertidal and shallow water habitat can affect primary productivity and, by providing habitat for predatory fish species, can affect aquatic habitat suitability. Approximately 34,240 square feet of new overwater coverage will be located over intertidal habitat at the site. The project also will result in approximately 4,279 square feet of new grated overwater coverage associated with a walkway to the proposed mooring dolphins. However, the grating, and the position of these walkways over deep water, will not result in impacts to primary productivity or other aquatic habitat function and no compensatory mitigation is proposed for these grated elements. Approximately inch steel piles will be placed for the structure as summarized in Table 5 below. The total includes a contingency of approximately 40 piles, to accommodate the potential need for additional piles as the structural design is finalized. This will represent a total of approximately 2,502 square feet of new benthic impact associated with new pile footprints and a permanent impact to benthic habitat. Of the total, 77 new piles representing approximately 969 square feet of benthic habitat impact will be located within intertidal habitats at the site. Underwater noise generated during pile driving can impact fish and marine mammals and airborne noise can impact certain birds and wildlife. Best management practices to reduce potential noise impacts include: Using vibratory pile driving to minimize disturbance Using noise attenuation methods (such as bubble curtains) to minimize noise during impact pile driving Marine mammal monitoring is mandatory for most pile installation activities. The monitoring will trigger shut down of pile installation at times when marine mammals (and/or selected endangered species) are in the project area. The project also will result in impacts to benthic habitat as a result of initial dredging of the expanded berth. The dredge prism and associated impact area and volume have been updated from the quantities reported in the original permit application submittal. The revision was initiated when it became apparent that an up to date bathymetric survey was needed to evaluate the existing mudline conditions at the site. A new bathymetric survey was completed at the site in December 2017 (Berglund Schmidt and Associates) and used to update the dredge prism design. The Hoquiam, Washington Page 23 of 26

28 revised dredge prism is smaller in volume and area than the dredge prism design that was included with the original permit application submittal for this project. Approximately 110,000 cubic yards of material will be dredged from an area approximately 7.49 acres in size to provide sufficient draft for vessels. The proposed berth will be approximately 4.72 acres in size. The dredge prism would be located almost entirely outside of intertidal areas, and the majority of the dredge prism would be located in areas already deeper than -30 feet. Dredging would convert approximately 9,246 square feet (0.2 acre) of intertidal habitat to subtidal. Dredging and material placement activities have the potential to result in short-term impacts to benthic organisms and their habitat, but these temporary impacts are not expected to significantly affect habitat suitability. Natural hydraulic processes routinely disturb benthic habitats at the site, and aquatic species that use this portion of the harbor are accustomed to these recurring disturbances. Dredged material will be placed at an appropriate permitted in-water or upland location as determined by the results of dredged material characterization in accordance with the Washington Dredged Material Management Program. Best management practices will be used to control and conduct dredging in a manner that reduces turbidity generation. Water quality monitoring of turbidity during dredging is mandatory. Table 5 summarizes the unavoidable aquatic impacts that will result from the project, and Table 6 summarizes the aquatic impacts by tidal zone. Table 5. Aquatic Impacts Area of Overwater Coverage (sf) Number of Piles Benthic Terminal Component 48-inch 24-inch Impact Solid Grated Steel Steel (sf) Permanent Mooring Dolphins Berthing Dolphins Quadrant Supports Transfer Tower Platforms Support Platforms Service Platform Pivot Supports Access Support Platform Access Trestle Spans Walkways Contingency Piles Total Permanent 48,114 4, ,502 Temporary Total Temporary Hoquiam, Washington Page 24 of 26

29 Habitat Zone Table 6. Aquatic Impacts by Tidal Zone Area of Overwater Coverage (sf) Number of Piles 48-inch 24-inch Solid Grated Steel Steel Benthic Impact (sf) Permanent Intertidal (above MLLW) 34, Subtidal (below MLLW) 13,874 4, ,533 Total Permanent 48,114 4, ,502 Temporary Total Temporary Construction may also require up to 48 temporary piles. Temporary pile use will depend on the method of construction for support platforms, transfer towers, access road platform, and pivot structures, as they are located in shallow water and may not be accessible by barge. Temporary piles will likely be 24-inch diameter, openended steel pipe piles, driven solely with a vibratory pile driver. Temporary piles may be installed for the mooring of a work barge during the construction and as templates to aid in the installation of the pile groupings. The temporary piles will be removed using vibratory equipment after construction of the relevant feature is completed. 8.3 Mitigation Mitigation for unavoidable impacts to wetlands and the aquatic environment will be implemented via on-site and/or off-site measures. The conceptual mitigation plan is currently being developed in coordination with the Washington Department of Ecology and the USACE. PHASE 5: LEDPA IDENTIFICATION This alternatives analysis was developed in accordance with the guidelines of the Clean Water Act Section 404 (b)(1) guidelines. The analysis demonstrates that Alternative A is the only practicable alternative and does not present significant environmental impacts. The unavoidable environmental impacts will be mitigated as determined in the forthcoming mitigation plan. The mitigation will be designed to meet the approval of the regulatory agencies. Alternative A is, therefore, considered the LEDPA for the project. BIBLIOGRAPHY BergerABAM Joint Aquatic Resources Permit Application (JARPA) Proposed Grays Harbor Potash Facility. September Ecological Land Services, Inc. (ELS) Wetland Delineation Report for IDD #1 Hoquiam, Washington. Prepared for Port of Grays Harbor, Aberdeen, WA. November Hoquiam, Washington Page 25 of 26

30 Parametrix Final Wetland Delineation Report Addendum. Grays Harbor Industrial Development District Property #1. Prepared by Parametrix, Bellevue, Washington. June Hoquiam, Washington Page 26 of 26