Submission Number: MBTL-EIS-0002200 

Received: 11/17/2013 10:02:05 PM
Commenter: Michael Riordan
Organization: San Juans Alliance
State: Washington

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
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Submission Text
Dear Lead Agency Representatives, I am a resident of Orcas Island in San Juan County, Washington, and a founding member of the San Juans Alliance, which is submitting a comprehensive statement including several areas of concern to people here in the San Juan Islands. I am also a member of Friends of the San Juans, which may also be submitting a separate set of comments. I share all the concerns stated in these comments, but would like to single out a few in particular. Recent NOAA research on the travel and feeding patters of Southern Resident Orca whales, an endangered species, indicates that these mammals often feed on Chinook salmon at the mouth of the Columbia River. The orcas are an especially treasured species in the San Juans, an iconic species that attracts tourists from around the globe and kayakers like me, who has paddled with these pods. They have recently lost members and there are only about 80 individuals remaining in these pods, a perilously low number the species is to survive. Therefore I am especially concerned about any adverse impacts that the Millennium Bulk Terminals project may have upon young and adult Chinook salmon migrating past it. These are listed (MBT) in detail in the collective comment made by the San Juans Alliance. An area in which I have particular expertise is fugitive coal dust releases, having studied such releases at several coal terminals in Canada and the United States, particularly the Westshore Terminals near Vancouver, BC, and the Ortran coal terminal in Duluth, MN. In general, one can expect releases of 3 to 10 grams of coal dust for every metric ton of coal transshipped, both from wind-blown coal dust from operations and during the loading process. While that may not seem like much, when multiplied by the millions of tons of coal to be shipped from MBT, it adds up to many tons of coal. For the projected 44 million tons annually planned for MBT, that would amount to 132 to 444 tons annually, about half of which would enter the Columbia River in the vicinity of the terminal. If major technological improvements in fugitive dust control could be implemented, these losses might be cut to 1-3 grams per metric ton, but that still amounts to 44 to 132 tons annually, or 22 to 66 tons entering the River. A large fraction of these losses during the loading process and are difficult to reduce because all the holds in the coal carriers must be kept open during the process so that the weight can be distributed evenly as the ship is loaded. For more details on the coal losses in the loading process, please consult my attached Comment on Coal Losses During the Ship-Loading Process, submitted to the EIS scoping process for the Gateway Pacific Terminal at Cherry Point. Therefore I specifically ask that your Environmental Impact Statement(s) address the following questions: 1. How much coal dust is likely to enter the Columbia River annually from land-based operations, including wind-blown dust from the storage piles? 2. How much coal dust is likely to enter the Columbia River annually from ship-loading operations? 3. What is the potential impact upon Chinook salmon feeding in the river downstream of the Millennium Bulk Terminals, including impacts upon forage fish favored by the salmon and of the dust settling upon and entering into the habitat of all these fish? 4. What is the potential impact that these coal dust losses from the terminal will have upon the endangered Southern Resident Orcas that feed upon these salmon at the mouth of the Columbia River? If the adverse impacts of these coal dust losses cannot be mitigated, I would hope that this project will be abandoned. Thank you for your consideration of and attention to this matter. Sincerely, Michael Riordan, Ph.D.