Submission Number: MBTL-EIS-0000076 

Received: 9/16/2013 5:11:00 PM
Commenter: Carolyn Gastellum
State: Washington

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
Attachments: No Attachments
Submission Text
From:Carolyn and Ed Gastellum <ecgastel@WAVECABLE.COM> Sent:Monday, September 16, 2013 5:11 PM Subject:Longview Scoping

Dear U.S. Army Corps of Engineers, Washington Department of Ecology, and Cowlitz County Commission,

I want our first grandchild, who is just fourteen months old, to have a future that is free from the most devastating impacts of climate change that is due to human activities. The only way that can happen will be as a result of the decisions we make now. We live in a global community, so deciding whether or not to allow coal export to Asia at a time when the United States is reducing our own coal burning power plants is a very serious matter.

I write to you as a person who firmly believes that the words "we are all in this together" have never been so true as right now when proposals involving coal mining in the Powder River Basin and the transport, export, and burning of this coal in Asia are under consideration in the Pacific Northwest. In particular, I am very concerned about the proposed coal export terminal in Longview, WA.

"Coal is the highest carbon emitter of the major fossil fuels....Scientists say emissions must peak within the next five years if the worst effects of global warming are to be avoided." (Fiona Harvey, The Guardian, October 28, 2012)

"If the countries of the world continue burning coal the way they do today, it will be impossible to achieve the reductions in carbon emissions needed to have a reasonable chance of preventing the worst consequences of global warming." (Union of Concerned Scientists, Options for Coal Around the World, May 1, 2009)

Please include in the scope of the EIS various statutes that fall under the category of the public trust doctrine. Under SEPA and NEPA federal and state agencies have an obligation to consider the broader implications of potentially exporting coal from Millennium Bulk Terminals Longview LLC Coal Export Terminal (MBTL) including climate change impacts. For example:

From SEPA: "The agency perspective should be that each generation is, in effect, a trustee of the environment for succeeding generations. Particular attention should be given to the possibility of foreclosing future options by implementing the proposal." SEPA, WAC sec. 197-11-440(5)(c)(vii)

Therefore, through a cumulative analysis for the proposed MBTL, determine the total amount of CO2 emissions that would result from the mining, transport by rail, export by cargo ship, and burning of 44 million tons of Powder River Basin coal over the life of the project. How will all these emissions impact and accelerate climate changes in Washington state? In particular, what will be the impacts on the glaciers of the North Cascades, on ocean acidification that is detrimental to marine ecosystems and shellfish, on precipitation that contributes to river and stream flow in the summer months that is crucial to salmon and agriculture?

What are the projections for extreme weather events in Washington that may increase due to the possible burning of coal that might be exported from both the GPT at Cherry Point and the MBTL in Longview? What would be the projected economic impacts due to climate change induced extreme weather events like landslides in the winter due to greater than normal precipitation or drought in the summer due to a decrease in precipitation in our state?

How much would the burning of the Powder River Basin coal in Asia that is proposed to be exported from both Cherry Point and the Longview Terminal offset the goals established by Washington State to reduce greenhouse gas emissions as adopted by our state legislature in 2008? "Washington State adopted greenhouse gas reduction standards via legislation adopted in 2008. (RCW 70.235.070(1)(a). The statute establishes that by 2020, emissions shall be reduced to 1990 levels. By 2035, GHG emissions are to be 25 percent below 1990 levels and by 2050, they are to be 50 percent below 1990 levels." (James Wells, Don't Pee In The Pool!, January 5, 2013)

In addition to greenhouse gas emissions, what are the health impacts from the mercury and other air pollutants that comes across the Pacific ocean from coal burning power plants in Asia? Levels of those pollutants can be detected now in our glaciers and waterways. What about ocean acidification? Recent studies ("Sea Change," by Craig Welch, Seattle Times, 9/15/2013) show a direct connection to acidic ocean waters due to coal burning. "As the burning of coal, oil and natural gas belches carbon dioxide into the air, a quarter of it gets absorbed by the seas, changing ocean chemistry faster than at any time in human history." Ocean acidification is already causing damage to Washington state's shellfish industry. What are the negative economic impacts to the shellfish industry and commercial fishing in our state?

How much worse will these impacts be over the life of the MBTL if that terminal is permitted? How much worse would it be if both the GPT at Cherry Point and the terminal at Longview are permitted?

Finally, please do a rigorous cumulative analysis of CO2 emissions from the MBLT and the GPT as well as the other coal export terminal that is being proposed in Oregon. What would be the overall climate change effects due to burning approximately 100 million tons of coal over the life of the proposed export terminals?

What would be the climate change, economic, human health, and ecosystem benefits if Powder River Basin coal is not mined, transported by rail, exported by cargo ships, and burned in power plants in Asia? I would like a comparative analysis that clearly shows the detriments of the coal export terminal proposals if they are allowed and the overall benefits to people in Washington and Oregon if the three proposed terminals are not permitted.

We must not foreclose future options for our children and grandchildren by accommodating increases in coal burning in Asia or any other place on the planet. It is the responsibility of our generation to take the lead in transitioning away from coal burning and other sources of greenhouse gas emissions and toward clean, renewable energy sources. Time is of the essence.


Carolyn Gastellum Anacortes, WA