Submission Number: MBTL-EIS-0002315
Received: 11/18/2013 8:55:08 PM
Commenter: Stephanie Buffum
Organization: Friends of the San Juans
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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UPPER COLUMBIA RIVER AND SNAKE RIVER CHINOOK SALMON ARE ESSENTIAL FOR THE SURVIVAL OF SAN JUAN COUNTY’S ORCA WHALES
The Southern Resident Killer Whales (SRKW), also known as the orca whale, is San Juan County’s icon. As noted above, our tourism-driven economy is dependent on these charismatic marine mammals. The birth rate of the SRKWs is strongly correlated with the abundance of Chinook salmon. New information shows that abundant runs of Columbia and Snake River Chinook salmon are important to the long-term survival of the SRKW.
Since the Southern Resident Killer Whale (SRKW) was listed as Endangered under the Endangered Species Act in 2005, the National Oceanic and Atmospheric Administration (NOAA) has funded studies of SRKWs to better understand how they can be protected. A key part of this effort is defining Critical Habitats that are essential for their traveling, foraging, resting, and reproduction. It is well established that SRKWs spend much of the summer near the San Juan and Canadian Gulf Islands, but winter sightings had been rare until a satellite-tracking device was attached to a young male SRKW in K pod. This NOAA-funded project has tracked the winter travels of the K pod of Southern Resident Killer Whales along the outer coast from the Strait of San Juan de Fuca to Northern California. K pod spent the most time between late December 2012 and early April 2013 around the mouth of the Columbia River. Because Chinook salmon is the preferred food of the SRKW, they were likely feasting on upper Columbia and Snake River Chinook salmon that were transiting these waters at the time.
Juvenile Chinook salmon use the lower Columbia River for migration and sustenance. Adult salmon must migrate along the Columbia River past the site of the proposed MBTL. Impacts associated with the proposed terminal, including fuel spills from vessels visiting the terminal, are potential threats to maintaining Chinook salmon runs adequate to sustain the Southern Resident Killer Whale population. Therefore we request that the scope of the EIS for the proposed MBTL include a study of impacts to this key salmon population that is federally listed as Threatened under the Endangered Species Act. Chinook salmon are also subject to further conservation considerations under the Fish and Wildlife Coordination Act, 16 U.S.C. 661-667e and the Magnus-Stevens Fishery Conservation and Management Act-Essential Fish Habitat, Pub. L. 94-265 and by international conservation efforts under the Treaty. As species listed under the Endangered Species Act, their defined critical habitat must be protected under law.
Please address the following impacts in the draft EIS for the MBTL:
1. What would be the impacts to Chinook salmon, and especially to juvenile Chinook salmon, caused by the construction of eight rail lines, two new docks, two ship-loaders, four coal stockpile pads, and associated facilities, conveyors, and equipment?
2. Because earlier industries have contaminated the river sediments surrounding the site of the proposed Millennium Bulk Terminals-Longview, what would be the impacts to Chinook salmon, and especially to juvenile Chinook salmon, of dredging the close to 400,000 cubic yards of contaminated river sediments necessary for the Millennium Bulk Terminals-Longview project?
3. What would be the cumulative impacts to Chinook salmon, and especially to juvenile Chinook salmon, of dredging contaminated river sediments near the Millennium Bulk Terminals-Longview site every few years to maintain access for Panamax-sized vessels?
4. What would be the impacts to Chinook salmon, and especially to juvenile Chinook salmon, of driving 647 new steel piles into contaminated river sediments?
5. What would be the impacts to Chinook salmon, and especially to juvenile Chinook salmon, of the shading caused by 647 new steel piles and two new docks?
See attached comment letter for additional comments on this topic.