Submission Number: MBTL-EIS-0002256
Received: 11/18/2013 3:52:38 PM
Commenter: David Henry
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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There are many legal questions that you are more than aware of here, but here but I am curious if you have considered the following:
1) If the cargo is solid or liquid that is an EPA regulated toxicant/pollutant, are the impacts of its transportation considered part of the scoping process of the action?
2) If the cargo is combusted into a gas (without EPA regulation) and transported back to the source area, are those resulting impacts considered part of the scoping process?
3) If this were a river, would it be allowed by Federal and state law to take a regulated pollutant upstream into Canada and dump it back in the river and not consider the impacts when the pollutant returns to US waters?
EPA studies in international transportation of air pollution suggests that downwind fallout from Asia would wipe out the air quality improvements in the US (See attached report) The Pacific air flow makes this situation similar to the situation in a river where the pollutant, in this case coal,is brought upstream and combusted and dumped back downstream in a far more harmful form. Why is this not legally required to be part of the EIS process?
In the case of Milennium Bulk Terminal, is Chapter 4 of NEPA (that requires "to look beyond the life of the action to address additive, countervailing and synergistic effects of the sustainability of resources, ecosystems, and human communities.") being integrated into the scoping process?
It is apparent that the scoping of this action must consider:
1) The upwind combustion of all potential products exported from this terminal including coal and Canadian tar sands oil on the downwind areas in particular Washington and Oregon marine waters.
2) The cumulative impact of all 5 proposed terminals, including the rail transportation from Wyoming across Montana, Idaho, and Washington and Oregon, the impacts on residential roads, and marine areas in the Columbia River gorge, increased shipping traffic along and increased local spill scenarios, future terminals on marine safety, and finally include potential spills in the narrow gap in the tumultuous waters of the Aleutians Islands, especially winter transportation conditions.
3) The economic impacts of downwind fallout on marine plankton, shellfish larvae, and WA state's $270 million-a-year shellfish industry that is one of the biggest in the world and employs roughly 3,200 people. This also includes salmon industry, local subsistence uses, forestry, and sea level rise.(See attached WA state report on the economic impacts of acidification)
4) The impacts of Asian Ballast Water on shellfish and fishing industries of Oregon and Washington already impacted by 30 listed species of Asian species displacing native species including the Chinese Mitten Crab, Asian Green Crab, Purple Varnish Clam. Ballast water impacts must be included in the EIS scoping Process.
5) Specific mpacts on Columbia River forage fish and Salmon populations.
On January 1, 1970, NEPA set forth a bold new vision for America. 43 years later will you uphold the law with new scientific knowledge that can document cumulative global impacts of actions?