Submission Number: MBTL-EIS-0000166 

Received: 9/6/2013 6:26:00 PM
Commenter: Lindsey Schromen-Wawrin
Organization: 
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:Lindsey Schromen-Wawrin <lindsey@world.oberlin.edu> Sent:Friday, September 06, 2013 6:26 PM To:comments@millenniumbulkeiswa.gov Subject:Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk Terminals Longview LLC Coal Export Terminal

Comment on scope of Longview EIS:

Any environmental assessment or impact statement that concerns fossil fuels must account for the impact that fuel will have - in its complete lifecycle - on the increase in greenhouse gas emissions and the subsequent impact on ecosystems and the earth system caused by climate change.

Anything less would fail to properly inform decision makers of the environmental impact of the action. NEPA requires informed decision making. Climate scientists recommend that society takes actions to reduce greenhouse gas concentrations to pre-industrial levels. Researchers are discovering that the negative consequences of not reducing greenhouse gas concentrations are more severe and far reaching than previously imagined. For example, ten years ago "ocean acidification" was not part of the common discourse on climate change impacts.

To reduce greenhouse gas concentrations, decisions makers must account for every new source of greenhouse gas emissions. Creating new sources - fossil fuel extraction - should be heavily scrutinized, because it pushes against the direction that climate scientists recommend for maintaining a viable earth system. Every new source, no matter how small, should be considered for its contributory impact on greenhouse gas concentrations. Each source could, in isolation, be considered to be marginal. No one source "causes" climate change. But that reasoning would lead us to conclude that climate change - one of the serious environmental issues of our day - would never be considered beyond a footnote in an EIS. Rather, regulators must take the opposite approach and fully consider the action's impact in causing climate change (and failing to mitigate climate change).

Thus, in considering the impact of building a coal export terminal in Longview, WA, the EIS should consider the entire lifecycle of the coal that would be transported through the terminal: Mining impacts Transportation impacts Consumption/Combustion impacts Mitigation impacts

This broad scope is necessary to properly assess the environmental impacts of the coal export terminal, which NEPA requires for informed decision-making.

Thank you, Lindsey Schomen-Wawrin

-- Lindsey Schromen-Wawrin 306 West Third Street Port Angeles, WA 98362 lindsey@world.oberlin.edu phone (360) 406-4321 fax (360) 752-5767 --