Allyson Brooks Ph.D., Director State Historic Preservation Officer

July 17,2013 Mr. Chris Jenkins Regulatory Branch Seattle District, Corps o f Engineers PO Box 3755 Seattle, Washington 98124-3755 Re: Gateway Pacific Terminal Project L o g NO: 092611-10-COE-S Dear Mr. Jenkins: Thank y o u f o r contacting our Department regarding t h e definition o f t h e Area o f Potential Effect (APE) f o r t h e proposed Gateway Pacific Terminal a t Cherry Point, Whatcom County, Washington. W e understand your identification o f t h e Area o f Potential Effect t o only include t h e actual terminal facility itself and t h e associated mitigation areas which include t h e entire 1,500 acre Project area a t Cherry Point. W e respectively disagree and believe there are clearly identifiable and reasonable foreseeable effects o f t h e Gateway Pacific Terminal Project t h a t indicate a greatly expanded APE which w o u l d include rail routes and seaward carriers. A reasonably foreseeable effect, t h a t requires an expanded APE, includes effects f r o m t h e increased rail traffic, and coal cars. The scope o f this project, and t h e associated train traffic, pose unique issues when developing t h e necessary cultural resource studies. The APE m u s t include a consideration o f t h e potential impact o f t h e rail portion o f t h e undertaking u p o n National Register listed o r eligible historic districts, Main Street program communities, and those jurisdictions w i t h local historic preservation programs (i.e. Certified Local Governments). Local preservation programs may have locally designated historic properties along t h e routes and t h e potential socioeconomic impacts t o these resources should b e part o f t h e APE. Therefore, t h e APE m u s t include all communities bisected o r traversed b y t h e rail routes in Washington. Please see t h e attached Figure t h a t documents t h e location o f Historic Districts, Main Street Program Communities, and Certified Local Governments. Additional considerations t h a t should b e within an expanded APE include construction o f additional track right o f way and spurs, direct and indirect effects o f train traffic including vibration t o historic structures, noise and traffic upon historic districts, and t h e impact t o archaeological and historic properties due t o derailments. Please see t h e attached Figure It h a t documents t h e location o f archaeological sites and districts along t h e rail routes.

State of Washington Department of Archaeology & Historic Preservation P.O. Box 48343 Olympia, Washington 98504-8343 (360) 586-3065

Mr. Chris Jenkins July 17,2013 Page 2

Another consideration f o r an expanded APE is t h e potential impacts f r o m t h e Rail Safety Improvement Act o f 2008. This Act mandates t h e r e q ~ ~ i r e m efnr n t Pnzitive Train Control Technology (PTC) f o r high volume freight traffic w i t h toxic hazardous materials. The needed infrastructure along t h e rail lines is a reasonably foreseeable effect o f this project and should b e included in t h e APE. There will also b e substantial coordination w i t h federal agencies w h o oversee changes and upgrades t o t h e rail lines. Will there b e a lead federal agency f o r this undertaking o r will all agencies conduct separate Section 106 consultations f o r this project? Panamax and Cape-sized dry bulk carriers along t h e Washington Coast and entering Puget Sound are clearly a reasonable and foreseeable effect o f t h e project t h a t should create a seaward boundary o f t h e APE. The increased vessel traffic, associated wakes, waves, a n d shoreline erosion o f these vessels and t h e increased risk o f accidents, oil spills, and damage all need t o be considered. We would appreciate receiving any correspondence o r comments f r o m concerned tribes or other parties t h a t you receive as you consult under t h e requirements o f 36CFR800.4(a)(4). These comments are based o n t h e information available a t t h e t i m e o f this review and o n t h e behalf o f the State Historic Preservation Officer in conformance w i t h Section 106 o f t h e National Historic Preservation Act and its implementing regulations 36CFR8oo. Should additional information become available, our assessment may b e revised. Thank y o u f o r t h e opportunity t o comment and a copy o f these comments should be included in subsequent environmental documents.

Allyson Brooks, Ph.D. State Historic Preservation Officer

State of WashingTon Department of Archaeology & Historic Preservation P.O. Box 48343 Olympia, Washington 98504-8343 (360) 586-3065

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