Submission Number: MBTL-EIS-0002308 

Received: 11/18/2013 8:45:34 PM
Commenter: San Juans Alliance
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
IMPACTS OF CLIMATE CHANGE AND SEA LEVEL RISE The MBTL at full capacity will ship 44 million metric tons of coal per year. It is expected that all of this traded coal will go directly to Asia. In doing so, both the transport and use of the coal itself, presents considerable risks that should be examined by the MBTL Environmental Impact Statement. The burning of coal releases carbon dioxide that contributes to global climate change. The adverse effects of climate change are those which result in changes to the physical environment or biota and which have significant deleterious effects on the composition, resilience, or productivity of natural and managed ecosystems or on the operation of socio-economic systems or on human health and welfare. The potential impacts of this change upon island communities such as the San Juan Islands are astronomical. The San Juans are comprised of over 450 islands, rocks, and pinnacles. These islands serve as residents, recreation areas, research sites, or nesting or breeding haul out sites for marine mammals and seabirds. They could all be adversely impacted by sea level rise. Washington State is believed to be particularly vulnerable to a warming climate particularly because of its snow-fed water supplies that provide drinking water, irrigation for agriculture and which are also responsible for nearly three-fourths of the state’s electrical power. In addition to the San Juan Islands, nearly 40 other communities, including some of the state’s largest population areas, exist along 2,300 miles of Washington’s shoreline, which is threatened by rising sea levels and ocean acidification. It has been estimated that if no action is taken, potential costs to Washington state from climate change impacts are projected to reach nearly $10 billion per year by 2020 from increased health costs, storm damage, coastal destruction, rising energy costs, increased wildfires, drought, and other impacts. Due to the severity of this threat, Pacific coast leaders in the United States have recognized this threat to their regional environment and economy and on October 28, 2013, leaders of California, Oregon, Washington and British Columbia signed the Pacific Coast Action Plan on Climate and Energy to begin to address these threats. Climate impacts to island communities are well documented. Small islands are at the forefront of the extreme risks posed by climatic change. The threat of, ‘possible adverse effects of sea level rise on islands’ was recognized in the United Nations Framework Convention on Climate Change (FCCC). It was added that such ‘small island countries’ are ‘particularly vulnerable to the adverse effects of climate change’. The ‘deep concern’ for small island (states) was reiterated at the 7th COP in 2001. This concern, which is continually reiterated by groups such as the South Pacific Forum, is due to their specific situation, which according to the 1994 United Nations Global Conference for the Sustainable Development of Small Island Developing States stated, While small islands developing states are among those that contribute least to global climate change and sea level rise, they are among those that would suffer most from the adverse effects of such phenomena and could in some cases become uninhabitable. Based on the tonnage of coal proposed to be exported and subsequently burned, we would request that the MBTL EIS include an analysis on the impacts of climate change on the San Juans. Please address the following impacts in the draft EIS for the MBTL: 1. What would be the impacts of the acceleration of climate change to San Juan County’s replacing public infrastructure (roads, water, sewer, and electric utilities)? 2. What would be the costs from associated increased storm winds, ocean surges, and precipitation on the San Juans from climate change? 3. What are the impact of sea level rise on marine mammal haul out site.