The removal of Edmonds Oil dock...

[Gill Envy]

section 2

I have made several phone calls to the various public servants in our state who are
responsible for the resources involved to get up to speed on the project and it's details. Below I have compiled a list of stakeholders that may be impacted by this project to help outline where I would hope there is additional consideration. Through my communications I have noticed that the Stakeholders appear to have some common ground that may make some kind of compromise in the plan more satisfactory for all involved. It is my biggest concern that while this is being done with all the best intentions that there may be some unintended consequences to the project, primarily the destruction of tens of thousands of aquatic creatures and the habitat they now call home. As a scuba diver of this state, I also fear loosing this feature, a wonderful shore access deep water dive.

Proposal for adjusting the plan for including more stakeholders wishes

After looking things over, I have noticed that many of the various stakeholder goals are not necessarily mutually exclusive. Public safety and environmental clean up are commonly held goals. I believe that much if not all of the public safety hazard and much of the environmental mitigation can be achieved without removing the more unique biological and recreational elements of the site. All the piping and all of the pilings could be removed from the eastern most part of the structure to the approach of the steep drop off. Some pilings could be left in place, chopped off, well above the high water mark, so they were visible to boats and the wading public with all over head pipes and support structure being removed up to the steep water drop off. Some of the supporting structure could be left above water in the deep water portion, being well out of reach of beach goers
and a solar powered coast guard light could be mounted on top of the structure to warn boats.

The above water section of the deep water portion of the dock

Much of the industrial waste could be removed from the above water portion, in the
western most, deep water portion, west of the drop off, leaving much of the support and shade structure (shade structure that does not limit the shallow water photic zone), leaving minimal public hazard but still providing shelter for schools of fish and the habitat that now houses a thriving ecosystem.

I would urge that an assessment be done of the entire ecosystem of the west end of the pier, an actual head count of Cabizon, Link Cod, ÅÃait fish, red rock crab, dungenous crab, rat fish all of which rely on the structure and it's food chain for survival. The head count should include the invertebrate population from sea bed to biologically active tide line before the demolition begins. I fear these populations have been overlooked, their abundance underestimated and their uniqueness under valued. I believe this site is a biological hot spot, which acts as a nursery and breeding ground for the surrounding area. With all the environmental regulation, it does appear that sometimes the only way to truly assess the value of a resource is to directly experience in person.

Points for consideration:

Currently it is understood that the two main drivers for this project are the confluence of the City of Edmonds desire to remove the public safety hazard and the WA state Ferrie System's identification of this project as a source for environmental Mitigation Credits needed for future projects that are impacting on the ecosystem at significant financial savings for those credits. I understand that every major environmental agency supports this move, including DNR, US fish and wildlife, nymphs, city ecology.

City/WSF Response:
Regarding your request to perform an assessment of marine life on or near the
Unocal Pier, the FEIS recognizes that the wood pilings of the UNOCAL and
existing ferry piers are heavily encrusted with barnacles and mussels. It also
recognizes that the barnacle/mussel encrustment, which can be 8 inches thick,
form a substrate supporting a rich community of organisms including amphipods,
various worms, and crustaceans, and ultimately larger shrimp, crabs, and fish
living in association with the pilings. The FEIS also recognizes that this
community would be removed when the pier is removed.

The SR104 Edmonds Crossing Draft and Final Environmental Impact Statements
and subsequent Record of Decision were reviewed by many agencies including
the following:

o Federal:
U.S. Fish and Wildlife
National Marine Fisheries Service
U.S. Coast Guard
Federal Highway Administration
Federal Transit Administration
U.S. Environmental Protection Agency
U.S. Army Corps of Engineers
National Oceanic and Atmospheric Administration
U.S. Department of Commerce

o State:
Washington State Department of Ecology
Washington State Department of Fish and Wildlife
Washington State Department of Natural Resources
Washington State Department of Transportation, including
Washington State Ferries, Office of Urban Mobility, and Rail
Branch

o Regional:
Puget Sound Air Pollution Control Agency
Puget Sound Regional Council
Sound Transit
Community Transit
Native American Tribes

o Local
Snohomish County
Kitsap County
City of Edmonds
Town of Woodway

 

[Gill Envy]

section 3

Issues and stakeholder alignment:

1. Public safety: local residents, visitor state residents, but primarily the City of
Edmonds, who property it is and who is ultimately liable for accidents/injuries.

2. The environmental toxin impact of current structure (such as creosote in the pilings, heavy metals and petroleum residues in aging industrial infrastructure): WA residents, Federal, state and local agencies.

3. The destructive environmental impact of removing the structure to the aquatic
residents: Environmental groups, Scuba divers, surrounding aquatic ecosystems.

City/WSF Response:
"As mentioned earlier, the FEIS recognizes that there will be an impact to the
aquatic environment. Addtionally, in 2008, the project went through consultation
with U.S. Fish and Wildlife Service and National Oceanic National Oceanic and
Atmospheric Administration as part of Endangered Species Act (ESA)
requirements, which confirmed the action was likely to adversely affect
listed species or critical habitat. Those services also provided guidance on
conservation measures related to removal of the pier."

4. Educational resource: park goers (School students/children, adults, including scuba divers, all of which gain inspiration and thus potentially respect for aquatic wildlife by having the opportunity to observe it.)


5. Recreational: Park Goers, including scuba divers, schools, etc, the pier helps make this area a destination site.

City/WSF Response:
While the existing Edmonds Underwater Park, located near Main Street, is one of
the few cold-water dive and training locations designed specifically to maximize
both the safety and enjoyment of divers, the Point Edwards/Unocal Pier area is
not recognized as an underwater dive park.

6. Transportation: future ferrie project: Residents of WA, WA State Ferries, Edmonds
City

City/WSF Response:
"Edmonds Crossing is a regional project intended to accommodate future growth
in travel along the State Route 104 cooridor which includes the
Edmonds/Kingston ferry run, provide a long-term solution to current operational
and safety conflicts between ferry, passenger/commuter rail, carpool/automobile,
bus, and pedestrian traffic, and reintegrate the Edmonds downtown core and
waterfront by removing ferry traffic from the downtown area. The Federal
Highway Administration, Federal Transit Administration, Washington State
Department of Transportation (including Washington State Ferries), and City of
Edmonds propose to develop a multimodal center that would integrate ferry,
commuter and intercity rail, and transit services into a single complex. A
realigned SR 104, from its current intersection with Pine Street, would provide
access.

The project is supported by the Puget Sound Regional Council Destination 2030
Metropolitan Transportation Plan for Central Puget Sound Region-Destination
2030; VISION 2020 - 1996 Updated Metropolitan Transportation Plan;
Washington State Ferries System Plan for 1999-2018; Snohomish County GMA
Comprehensive Plan Transportation Element; City of Edmonds Comprehensive
Plan; and Port of Edmonds Strategic and Master Plans. "

7. Environmental Mitigation credit opportunity: WA state Ferries, Puget sound Transit

Goals:

1. public safety: It's my understanding that the existing above water portion of the oil dock has been identified as a safety hazard due to damaged support structures that are gradually failing over time and could conceivably fail unpredictably causing mortal injury to those who go under the structure and climb on it from shore. Potential for injury to children visitors seems particularly compelling due to the fact that the structure has been one of the main attractions for invertebrate viewing during minus tides.

City/WSF Response:
"As stated during a phone conversation on October 17, 2008, the City of Edmonds
does not allow any person to use the Unocal Pier for any reason. As owner of
the Unocal Pier, the City does not want to risk leaving the Pier in its present
condition. "

2. The environmental impact of current structure: One of the intentions is to remove a long term source of toxins from the environment. Also Reducing Over water coverage (shading in the photic zone), particularly for increase potential eel grass habitat, which because it is considered prime habitat for salmon rearing, involves elements of the Endangered Species Act. The Nepa, national environmental impact assessment, starting in 2005 for the new Edmonds terminal, helping to assure that proper protocol has been
carried out.

City/WSF Response:
"At the request of CH2M Hill, an inspection of the Unocal Pier, including dock
buildings, piping systems and walking surfaces, was performed in 2001.
Inspections were performed to locate, identify and quantify contaminants. These
systems were found to contain asbestos, lead, and all light ballasts are assumed
to contain PCBs. 2008 studies performed by Landau Associates confirmed the
existence of these contaminates as well as noting the potential for mercury in
electrical switches on the pier."

 

[Gill Envy]

section 4

3. The destructive environmental impact of removing the structure to the aquatic
residents: tens of thousands of creatures will be destroyed in the abrupt removal of this structure the pier is in a tidal current convergence zone which supplies nutrients to an unusually abundant and thriving community of invertebrates and other sea creatures which now rely on the structure for shelter and a solid substrate to attach. My fear is that in all the efforts to conform with environmental regulations, that harm to current aquatic residents have not actually been accounted for fully, as if the fact that they live on a man
made structure somehow negates their value. I want to make doubly sure that the
abundance and diversity of the creatures at the various levels of the water column of this structure have actually been taken into consideration and are fully understood I have yet to hear if anyone doing the impact studies actually researched the actual aquatic population of this structure directly, by diving the site. From what I can tell, having done some 600 dives in the Puget sound, this is a relatively unique site with an incredible abundance of sponges, tube worms, nedubranchs and other surprisingly exotic looking invertebrates, most of which rely on the structure to live there. An entire food chain has developed there, from microbe to large bottom fish. Their beauty, when seen in person is much more awe inspiring than anything that could be written about them or filled away in
a report.

Of particular note is the top 30 feet, from the mid tide zone down about 30-40 ft, which contains near 100% saturation of invertebrate life, a rarity in these cold waters. This section is really a small percentage of the overall structure of the pier.

City/WSF Response:
"As a part of the Draft FEIS process, a Vegetation, Fisheries and Wildlife discipline
report was prepared. As mentioned earlier, the FEIS recognizes that the wood
pilings of the UNOCAL and existing ferry piers are heavily encrusted with
barnacles and mussels. It also recognizes that the barnacle/mussel
encrustment, which can be 8 inches thick, form a substrate supporting a rich
community of organisms including amphipods, various worms, and crustaceans,
and ultimately larger shrimp, crabs, and fish living in association with the
pilings. The FEIS also recognizes that this community would be removed when
the pier is removed.

The removal of the pilings will also provide an opportunity for the Point Defiance
Zoo & Aquarium to collect invertebrates living on the pilings for a new exhibit.
The Seattle Aquarimum will be collecting various species to supplement existing
exhibits. Removal will also provide the opportunity for documenting and
eradicating occurrences of Didemnum, an invasive non-native species of
tunicate. "

4. Educational Resource: Many people find this site to be a source of inspiration,
discovery and wonder, above and below water.

5. Recreational: Recreation and education are related but different. This pier offers a destination and subject point for both terrestrial and aquatic exploration and
entertainment. For Scuba divers this site offers a unique combination of public shore access, substantial substrate, a steep drop off for deeper diving and abundant marine life due largely to significant tidal currents and massive structure, making it an excellent place for recreational and moderate technical to scuba diving. It's my understanding that Edmonds City does not have a specific stance against diving at this site, but rather sees the underwater park north of the pier to be designated for such. It should be noted that due to the combination of micro currents and massive substrate it is vastly different from the underwater park that is only a mile away, both sites have their own unique aquatic communities.

City/WSF Response:
"As stated earlier, while the existing Edmonds Underwater Park, located near Main
Street, is one of the few cold-water dive and training locations designed
specifically to maximize both the safety and enjoyment of divers, the Point
Edwards/Unocal Pier area is not recognized as an underwater dive park."

 

[Gill Envy]

section 5

6. Transportation: Port of Edmonds crossing project, started in 1993, is intended to
address the growing demand for ferrie service in the area. There are no certain plans to put this ferrie slip in, nor time line for it's addition and the preliminary plans do not involve the land that the Oil dock is currently on. My understanding is that at one point the Oil Dock was considered as a parallel site for a new Ferrie terminal but that that has now been dropped, eliminating one of the reasons for removing the oil dock. There are sketches that show a Ferrie Terminal going in roughly 800 ft to the north, well outside the ÅÏo go zone of the future ferrie slip.

City/WSF Response:
"Alternative 2, the preferred alternative includes plans to construct holding
lanes/pier west of the existing BNSF rail lines along the north side of Marina
Beach Park and south edge of the Port of Edmonds. Construction of Edmonds
Crossing is dependent on the availability of funding. The lack of an identified
construction funding source does not necessarily mean that a proposed timeline
does not exist.

As an identified mitigation measure, the Final Environmental Impact Statement
calls for removing UNOCAL Pier. The Alternative 2 Preferred Alternative
alignment (vs. the 1998 Draft FIES alignment) of the Edmonds Crossing pier,
located west of the BNSF rail line, is not considered by any agency as a reason
for not removing the existing UNOCAL Pier. Even if removal of the UNOCAL Pier
were not identified as a mitigation measure, the pier has structural integrity
issues, contains contaminants, and presents a visual and physical barrier, both
on land and in the water. "

7. Mitigation credit opportunity: various government agencies that are involved in
projects which impact the natural resources of WA state/this country are required to mitigate the impact of future project by first helping to fund clean up projects, a kind of ÅÄlean up for future damage swap? As more clean up projects are completed the number of such mitigation credit opportunities diminishes, causing competition to builds for such sites, leading agencies to vie for the remaining sites so they can move forward with other installation projects. WA state Ferries has identified this site as a particularly viable for such a mitigation credit opportunity as the open willingness of the Edmonds city to have it removed reduces the cost of the project, while the credits for it remain high. Puget sound Transit is a potential competitor should WA state ferries pass up this opportunity, leaving few near by projects to attain the mitigation credits that the WA state ferries need
for future projects in the area.

City/WSF Response:
"As mentioned previously, over an 11-12 year time frame, many individuals,
agencies and consulting firms, participated in the preparation of environmental
documents and design elements of the project. Consultations were also
conducted with local tribes and nations. Additionally, public meetings and
presentations were conducted and presented respectively, providing many
opportunities to submit comments and suggestions. As a result of this lengthy
process, Alternative 2 was chosen as the preferred alternative? Related
environmental enhancements were also included as a part of the environmental
process and removal of the Unocal Pier was widely supported. "

a source of education for the public on the impacts both positive and negative with
respects to human impact on the environment, and as a wildlife viewing area both
above and below water of the creatures that have adapted to and become dependent on it's existence.

It is my hope that we can find a way of meeting the greatest number of stakeholder needs, by making an adjustment to the plans.

City/WSF Response:
"Leaving any portion of the pier, whether submerged or above the water line,
would result in long term inherent costs to the City, e.g., maintenance,
identification markers and signage, lighting, etc. Considering the City short and
long term financial situation, this is not something the City is prepared to
undertake.

Washington State Ferries and the City have been working for quite some time to
secure funding to pay for removal of the pier, prepare plans, and solicit bids.
Additionally, the window or timeframe when such removal activities can take
place is near and it's important that removal of the Pier take place within the
November, 2008 March, 2009 timeframe. We hope you understand the need
to move forward with our original plans"

Sincerely,
Shoreline Resident

 

[Scuba-Stu]

Thank You.

 

[Gill Envy]

this just in:


The City of Edmonds has received written notification that Washington State Ferries and Manson Construction will begin removal of the Unocal Pier on Monday, November 24, 2008 through February, 2009. The City will be posting signs this week at Marina Beach informing park users about the project along with notification that no scuba diving will be allowed during pier removal operations.

Thanks,

Stephen

Stephen Clifton, AICP
Director
Community Services & Economic Development
121 - 5th Avenue North
Edmonds, WA 98020
425-771-0251


___________________

since I did not hear back from a mod, I posted my letter with official response on another site, you can find it here:
http://www.scubaboard.com/forums/pacific-northwest-orca-bait/260371-removal-edmonds-oil-dock.html

if there is anything that can be done, it has to happen really soon! Ideas anyone?

 

[MXGratefulDiver]

Ask 10 researchers whether the pilings are "polluting" the water and you will get 12 different answers. The consensus seems to be that any creosote that was in the below-water parts vanished decades ago. Apparently the thousands of anemones, sponges, nudibranchs, bryozoans and other critters that call those pilings home didn't get the memo about it being bad for them.

Dave ... that's not really a good argument. I mean ... humans have known for more than 40 years that smoking's bad for them, but millions still smoke ... and humans are supposedly smarter than anemones ...

... Bob (Grateful Diver)

 

[Gill Envy]

Dave ... that's not really a good argument. I mean ... humans have known for more than 40 years that smoking's bad for them, but millions still smoke ... and humans are supposedly smarter than anemones ...

... Bob (Grateful Diver)

I see your point Bob, the question here is not weather we should keep adding Creasote by continuing to use it in the construction of pillings, that's has been discontinued. this is more like the guy who smoked for many years then quit many years ago ... seems the damage has already been done and things are likely improving on their own. I think the question is, are the pilings that were placed there some 80 years ago still offing significant amounts PAH. I wish there was more solid research on this. I suspect that most of the bad stuff is in the sediment below the pilings... and there are no plans to remove that...sigh. dredging the bottom regardless of what happens to the pillings might just do more good.

The salmon and then the Orcas (who, it was explained are the ultimate target of the trend to remove sources of creasote) are probably bio-accumulating PAH and other nasty's from stuff that was released a long time ago that resides systemically now. Another theory that has been explained to me by some researchers on San Juan is that the Orcas are accumulating more of the nasties because they are running out of salmon to eat and have to eat bottom fish, thought to have absorbed more of the toxins because they live so much longer and feed in the sediment.

kind regards,
george

 

[H2oGrl]

Hi Gill Envy and fellow lovers/divers of the Edmonds Oil Dock!

Like many I recently found out about the plans to remove the dock. Having dived this spot for over 13 years my heart sunk. The abundance of life on and around the dock will suffer from the full removal of the pilings (aka: artificial reef). Many inhabitants on the pilings will not be able to pick up and move. The removal of the dock will mean the end of their lives. The vast diversity and amount of fish that depend on the dock year round for life, and the ones who come back year after year to lay eggs, will need to look for new homes.

As someone who was born and raised in the Pacific Northwest I want nothing more then to see the beauty of our home well stewarded and respected by each and every person. This does include the belief that toxins coming from pilings could be done without. It also includes the belief that all our marine life is precious and that they should not be punished for having adapted to living with what we've created. There can and should be a way to make this a win-win for every Being concerned.

Is there time to rally concerned citizens to the December 2nd Edmonds City Council meeting? Can we bring our stories, photos, videos and forward-thinking solutions? Can this be made a win-win for the citizens of Puget Sound, our marine critters, and our waters?

Anyone up for helping plan a much needed trip to a council meeting?


-LeAnne

 

[Gill Envy]

Hello LeAnne, I would be happy to show up if you have details please pm me. here are the areas of concern I have that may give folks some traction:

-many of the toxic substances are in the above water section of the structre and can be removed without destroying the artificial reef.
- I do not believe it's know if the pilings are still leaching PAH (they are more than 80 years old)
- I do not believe there are plans to test for PAH in the silt and remove/dredge the sediment under the structure... where the highest concentrations of nasties are likely to be.
- I did not get a straight answer as to if anyone has actually done a head count of the critters that will be killed or left without a food chain, which I find is not a requirement of the impact statements... seems strange that you can do an impact statement without knowing what will be destroyed?!
- It's clear that Divers have no rights in this, and will likely get little to no sympathy as we are seen as a minority population who's judgment is biased and self serving... when in fact we are the ones with the first hand experience of what is actually living there... something that can not be garnered from a desk while pushing paper, let alone from looking at the structure from the surface.
- I don't think the tribes are aware of the large populations of bate fish supported by the food chain there that could be argued are good for salmon... I forget who told me that might be a leverage point.
- few of the pictures I've seen really illustrate the density and diversity of life in the top thirty feet of the pilings out in the deep water section... it's an amazing reef!
- if there were a way to get DNR to take on the reef and not charge the city to maintain it, I think we'd have a much better chance of succeeding... this thing will be an ongoing drain to the city's finances unless an alternative to the current lease fee structure is found.

I wish we had more time to organize, i've been hamstrung by an ailing father, a house remodel and a baby on the way on top of my usual work responsibilities... we all have to choose our battles wisely. it may still be that if enough people come together to talk with the locals that some kind of comprimise could still be reached, I just know I can't do much more than I have ... hope springs eternal!