Submission Number: MBTL-EIS-0002295
Received: 11/18/2013 7:23:34 PM
Commenter: Michael Hartwell
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
Thank you for the opportunity to submit comments for the scoping of this project.
My greatest concern for this project lies in a complete disclosure of the cumulative effects in the EIS. Because the project would result in greatly expanding export capabilities and infrastructure to an ever expanding and seemingly insatiable market for coal abroad, there will be undeniable impact to air and lands.
Climate change needs to be analyzed as a potential effect. The act of broadening markets opens up more opportunity and feasibility for resource extraction in the interior US. The analysis should incorporate a thorough economic analysis of international demand and trends and look at potential port capacities. It is the port capacities that will give a true measure and reflection of the potential cumulative impacts. Identifying a single port capacity or number from market trends may be foreseen as speculation, however there is clearly potential impact if there is any functional capacity at all. Therefore I suggest analyzing several capacities so that range of potential impacts may be analyzed. These numbers should be used to provide a hard look at potential CO emissions from spent coal, potential impacts to shipping and mineral extraction corridors.
The lead agencies should also analyze and incorporate by reference any past present or foreseeable federal special use permits throughout the coal source areas that would be potentially shipped through the ports. The facilitating any mining activities on private lands or publicly mined lands that have created coal supply large enough for proposed action to be considered. These are all cumulative and related actions, i.e., one, or the collective of many would not occur without the other.
Lands within the interior US that would be more feasible to mine need to be considered as well. Potential minable lands need to be examined as potential impacts as a result of the port expanding and facilitating larger international markets. Prime farmland, water and impacts to any other special lands (i.e., wetlands, special habitats) need to be considered. Past, present and future infrastructural improvements to accommodate larger coal rail traffic needs to be considered in analysis along the corridor from the Powder River Basin to the port. BNSF and all their subcontracted railroads should be included as well as any other railroad service that would play any part in carrying coal to the proposed port.