Submission Number: MBTL-EIS-0002027
Received: 11/13/2013 11:07:51 PM
Commenter: Kim Abel
Organization: League of Women Voters of 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
November 13th, 2013
Dear Cowlitz County, Washington State Department of Ecology and Army Corps of Engineers,
The League of Women Voters of Washington is strongly committed to arresting climate change, as well as preserving and restoring environmental quality for the benefit of future generations.
The League of Women Voters of Washington urges that the EIS scoping include the broadest range of impacts from the construction of the Millennium facility and associated transportation by rail and ship, up to the point at which the coal is consumed. To consider this proposal in a vacuum would fail to provide a realistic description of the actual impacts of this project on the human environment.
The EIS should consider potential local impacts to human health, especially any that could develop as coal dust and particulate matter escape from rail cars and from loading facilities. It should also study the business and social costs resulting from traffic disruption and congestion as trains cross over highways and arterial and local streets. It should deal with the possibilities of spillage, and of coal dust that would be dispersed in marine water, with attendant risks for both the flora and fauna and the economic costs of spills to those who use the same waters for recreation and livelihoods.
Beyond such local and regional impacts, it should also deal with the cumulative impacts of this project in concert with other proposals to transport, process and export large quantities of fossil fuels, including the other coal export proposals, oil shipment proposals and the proposed LNG proposal at Warrenton, Oregon. Perhaps the best approach would be to prepare the draft EIS for each of these proposed projects and then prepare a final EIS that looks at their impact in the aggregate. In other words, a final EIS should consider the cumulative impacts of all fossil fuel transport and export projects that impact Western Washington.
While proponents of this project (and others like it) frequently argue that the EIS must be drawn narrowly, and should by no means include reference to the global carbon footprint, the scale of this proposal is such that the omission feels a lot like ignoring the elephant in the room. This project alone could export up to 60 million tons of coal. The three Pacific Northwest port proposals combined would export well over 100 million tons, and the burning of that coal at its destinations would add 200 million metric tons of carbon dioxide to the atmosphere.
In any case, since the atmosphere does not respect international borders and boundaries, it would seem that an EIS on a project of this magnitude would be incomplete with at least a general reckoning of how consumption of the product will impact the global carbon footprint and the health of those communities downwind. Coal burning in Asia will have an impact on the environment in the Pacific Northwest, and thus should be considered.
Thank you for your attention to our comments.
Kim Abel, President
League of Women Voters of Washington
Empowering all Washingtonians to engage in a more responsible & responsive democracy
1402 Third Avenue, Suite 430 Seattle, WA 98101
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