Submission Number: MBTL-EIS-0002294 

Received: 11/18/2013 7:23:01 PM
Commenter: Madeleine Brown
Organization: Lower Columbia Basin Audubon Society
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
Scoping comments for environmental impact statement for the Millennium Bulk Terminals-Longview coal export proposal The Lower Columbia Basin Audubon Society promotes the conservation of wildlife and wildlife habitat. We are concerned with both local and global threats to wildlife and birds. Thus, we oppose the proposal to ship the coal mined in Montana and Wyoming to Asia. The coal will harm human health and the environment during its mining, transportation, and especially its burning, which will increase greenhouse gas emissions, and toxic air pollution, in Asia and in Washington state. Below are our comments on what your environmental studies’ scope should include. The state and county EIS under SEPA must address elements the state called for in environmental studies in Oregon. • Cumulative effects from the other coal export proposals as well as the Millennium Bulk Terminals – Longview. • Fugitive dust from the coal, en route and at export facilities. • Derailment and spill prevention and response, especially in sensitive and scenic areas. • Overall rail capacity. • Impacts on commuter and AMTRAK service. • Traffic impacts from increased train traffic. The study must consider the state’s laws and executive orders EO 07-02 and EO 09-05 addressing climate change. The study must look at the impacts of increasing levels of methylmercury in the waters of the state and the fish, in light of the grim reality that coal emissions put mercury in the air, and global air patterns bring the toxic emissions back to the American west coast. The study must include in the cumulative impacts the proposed liquefied natural gas transport and export proposals. The study should address negative economic effects from decreases in property values, contribution to urban blight, damage to fish and shellfish resources. The study should address harm to the Columbia River from Finley to the mouth of the river, including estuaries and wetlands. The study should address environmental risks from the hazards at the river’s mouth. The study should address environmental impacts from the strip mining in the Powder River Basin. The study should address the risks from the coal’s combustibility, particularly in light of the limited fire fighting resources in the Columbia Gorge. The federal study must address adverse economic impacts since the coal’s adverse environmental impacts are a certainty. The study must address harm to rare, threatened and endangered bird species from the mining, coal dust and increased emissions from the trains, export, and ultimate burning. The study should address impacts from bad and worsening weather, as climate change leads to more extreme weather events today. The needs section warrants close scrutiny. Evaluate who will benefit and who (and what) will bear the harm from the proposal. Review the proposal through the lens of environmental justice. Dirty and dangerous proposals continue to be sited near poor, disadvantaged, or economically stressed communities. The proposal runs counter to state and federal commitment to environmental justice, and the state’s holistic approach to sustainability. The study should consider the intangible but likely quantifiable harm to Washington’s reputation as a clean and green—Evergreen State.