A vibrant and healthy economic and environmental future for the ports is vital to us all.
We must meet the ports' environmental challenges. But to do this, it is essential that we build needed marine and landside shipping facilities and improve our transportation corridors. Without these improvements, congestion and air quality will only worsen. Inaction or delay is not an option .In order to green the ports, we must grow them.
FuturePorts supports greening and growing our ports.
You can download a Word version of this letter here.
July 31, 2007
Dr. Spencer D. MacNeil
U.S. Army Corps of Engineers, Los Angeles District
P.O. Box 532711
Los Angeles, CA 90053-2325
Dr. Ralph G. Appy
Port of Los Angeles
425 S. Palos Verdes Street
San Pedro, CA 90731
Re: TraPac Draft EIS/EIR
Dear Dr. MacNeil & Dr. Appy,
On behalf of [ORGANIZATION NAME], we would like to congratulate the Port of Los Angeles, commissioners and staff for producing the draft EIS/EIR for the TraPac Container Terminal Project. This is the first step in ensuring that our ports can efficiently manage expected growth while mitigating environmental impacts. This project represents an important step to ensure green growth at the Port of Los Angeles. We hope that the Port will continue this momentum by moving forward with draft EIRs for future projects that will follow swiftly on the heels of the TraPac project.
As you are well aware, the Ports of Los Angeles and Long Beach are a major economic driver, providing approximately 500,000 jobs in the greater five county region and more than 3 million jobs nationally. At the same time, the ports are potentially facing a major capacity crisis. In its May forecast, LAEDC predicted that the ports will grow 9.2% this year to 17.2 million TEUs. (The ports essentially predict a 6.4% increase to 16.8 million TEUs.)
We firmly believe that port growth, and the appropriate accommodation of that growth, is critical not only to the Southern California and national economy, but also to our air quality.
Re-development of the TraPac terminal is an important step towards efficiently managing the expected growth in container volume and mitigating environmental impacts. Terminal efficiency will nearly double, while minimizing truck idling and increasing use of rail. As a result, the EIR shows that the proposed project will reduce emissions of greenhouse gasses and criteria pollutants below baseline levels.
The proposed project also meets the green growth goals of the Clean Air Action Plan (CAAP) and significantly reduces health risk to local communities several through numerous environmental features. In addition, a 30-acre landscaped buffer zone separating the community from port operations would provide much needed green space and recreational facilities to community members. This project exceeds the obligations and authority granted under CEQA. If TraPac agrees to the additional mitigation that is fine, but it should not be considered as precedent for other CEQA projects. Additional mitigation should be considered outside of the CEQA process and implemented by voluntary agreement.
Conversely, the "no project" alternative clearly shows that a failure to complete this project is detrimental to air quality in the local community and the region. In fact, even if no changes are made to the facility, the container cargo volume at the TraPac terminal is expected to nearly double without any of the environmental benefits of redeveloping the site. Moreover, it's clear that certain improvements can only be provided with the site redesign outlined in the EIR.
The draft EIR for this project is a very comprehensive document, and we understand the time and effort that went into preparing it. The TraPac project has many positive elements that will enhance efficiency and reduce emissions, and we support all of terminal enhancements that will allow for "green growth" to occur. We believe that we have common goals with the Port: to grow the port and clean the air. However, we have concerns with some of the mitigation measures as outlined by the CAAP. We believe that some of the proposed measures go too the extremes and are not good for business, such as the current truck plan. We do not believe that all of the proposed measures are the most efficient and cost effective ways to get clean air.
While we may not agree on every aspect of the TraPac project draft EIR, we do agree that that we have a common goal of green growth, and we look forward to continuing our work together to find solutions on how best to accomplish our mutual interests and move these projects forward.
We believe that the proposed project represents an important "green growth" initiative to provide more efficient goods movement through the Port of Los Angeles with a concurrent reduction in emissions. We therefore support the project with some exceptions to the mitigation measures, and encourage the Port of Los Angeles to continue moving the approval process forward quickly to completion while following a fair CEQA process.
Sincerely,
[NAME]
[TITLE]
