Northwest Environmental Advocates--Channel Deepening

Columbia and Willamette Channel Deepening Project, cont.

Secondary & Cumulative Impacts of Channel Deepening

West Hayden Island, Port of Portland Development
Vancouver Lowlands, Gateway Development Project, Port of Vancouver
Ross Island
Portland Harbor Superfund
East Hayden Island, Toxic Landfill
Invasive Species

Endangered Species Act (ESA) implementing regulations define 'cumulative impacts' as those effects caused by future projects and activities unrelated to the action under consideration that are reasonably certain to occur within the action area. They may also include "growth inducing effects and other effects related to induced changes in the pattern of land use, population density, or growth rate." The Final Environmental Impact Statement (Final EIS) fails to address the reasonably foreseeable cumulative impacts of the channel deepening to include those actions from other public agencies or private entities that are, in fact, linked to channel deepening. These other dredging actions include activity near ports, marinas, and harbors where, owing to their proximity to the shore are highly likely to contain fine-grained and/or contaminated sediments. The interdependent and interrelated actions due to channel deepening, such as dredging by ports and private individuals, could occur in areas with a higher degree of contaminated fine materials. Bottom materials in these areas outside the channel have not yet been well characterized, and depositional areas containing organic materials could be under-represented during the sampling process. These actions are related to channel deepening and could result in secondary impacts, i.e., resuspension of contaminants which would effect salmon, bald eagles, mink, otter, and other fish and wildlife.

Deepening of ship berths and access channels are two examples of projects that will cause further impacts to salmon and salmons habitat, impacts that NMFS is required to evaluate. However, while NMFS allows that "facilitation of vessel transport" continues to lead to the expansion of port facilities all along the Lower Columbia, (ie Port of Portland's West Hayden Island project and Port of Vancouver's proposed Gateway Development Project,) they calls the factors "difficult to quantify" and "appropriately addressed" by long-term restoration programs. The Corps continues to deny that the Port of Vancouver's plan to use dredge spoils from the deepening project to fill over 600 acres of valuable habitat at the Gateway 3 site in the name of port development is a connected, cumulative, and similar action. The Final EIS does not disclose nor does it analyze the environmental impacts of this connected port development, which, instead, is billed as beneficial use of dredge spoils. Regardless of whatever alleged development benefits are associated with this action, the environmental cost must also be fully assessed in this Final EIS. We find that the added impacts of secondary and cumulative effects, combined with the direct impacts of the project, are worth quantifying before the project proceeds.

In attempting to assess impacts on future port development -- like the Port of Vancouver plans that will further degrade riparian, wetland, and upland habitat, -- the Corps makes the following prediction: "Actions related to channel deepening would include: …continued development of port facilities to meet future needs; and contributing to the maintenance of current levels of economic and population growth in the region." Vol. I at 6-57. Yet in direct contradiction, the Corps states "channel deepening in itself would not induce additional ship traffic. Likewise, it would not contribute to development of additional ports or port facilities." Vol. I at 6-51. First, the Corps states that channel deepening would contribute to port development, then it says channel deepening would not contribute to port development. If it will, then the FEIS must by law, evaluate those connected impacts, which it currently does not. 40 C.F.R. § 1508.25. If the channel deepening will not contribute to port development, then the FEIS must clearly state so and substantiate its claim.

[11Y] West Hayden Island, Port of Portland Development