Submission Number: MBTL-EIS-0002318 

Received: 11/18/2013 9:00:54 PM
Commenter: Stephanie Buffum
Organization: Friends of the San Juans
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
CUMULATIVE SHIPPING IMPACTS ON NATINAL WILDLIFE REFUGES (FROM THE COLUMBIA RIVER TO ALASKA) Marine shipping by its very nature requires a rigorous assessment of all direct, indirect and cumulative impacts on the route of the cargo from MBTL up the coastline of Oregon, Washington, and British Columbia and through Alaska. Because NEPA and SEPA do not place a time or location restraint on reasonably foreseeable adverse impacts, our request is within the purview of the EIS we believe that this EIS requires an analysis of Alaska’s National Wildlife Refuges and National Wildlife Refuges in Washington State, including the fish and wildlife dependent upon these Refuges; the air, water, marine, and terrestrial environments in these refuges; and the communities, economies, and cultures that rely on the health of the natural systems that sustain these refuges. Alaska has 16 wildlife refuges that are part of the National Wildlife Refuge System. 83% of all National Wildlife Refuge lands in the U.S. are located in Alaska. The Alaska Maritime National Wildlife Refuge (Alaska Maritime Refuge) contains more than 2,500 islands, islets, spires, rocks, reefs, waters and headlands that extend from Forrester Island, to the north of Canada's Queen Charlotte Islands deep in the southeast tongue of the state, to the westernmost tip of the Aleutian Islands, and north to Cape Lisburne on the Arctic Ocean. The 3.4 million acres of the Refuge are spread out along most of the 47,300 miles of Alaska's coastline. There are five units within the Refuge: Aleutian Islands Unit; Gulf of Alaska Unit, Bering Sea Unit, Alaska Peninsula Unit, and Chukchi Sea Unit. The Refuge protects essential habitat for seabirds, shorebirds, waterfowl, marine mammals, fish, and other wildlife. The Refuge contains one of the most important marine ecosystems in the world. Its isolated islands host unique species not found anywhere else. The Alaska Maritime Refuge is home to more than 40 million seabirds (80% of all the seabirds found in Alaska) representing more than 30 species. These birds forage for fish and plankton in the seas surrounding the Refuge. Some 250 migratory bird species, including rare species from Asia and North America, use the Refuge. Some species and subspecies of birds in the Refuge are found nowhere else. Some of the birds that nest on the refuge – including Whiskered, Crested, and Least Auklets, Red-legged Kittiwakes, Aleutian Terns and Red-faced Cormorants – live and breed solely in the core Bering Sea-North Pacific Ocean zone. Thirty Maritime Refuge sites (including Unimak Pass identified as a top Important Bird Area (IBA) based upon bird abundance and diversity) have been identified by National Audubon as IBAs of the Bering Sea Eco-region under an international bird conservation program spearheaded by Audubon Alaska with Russian and Asian partners. (An IBA is an international designation used in more than 150 countries to indicate that an area harbors bird species of special concern, species with restricted home ranges, and species that are vulnerable because they exist in high concentrations and therefore could suffer significant negative impact from a single event). Birds found in the Alaska Maritime Refuge, including individuals of 58 species in the Aleutian Islands Unit, 60 species in the Alaska Peninsula Unit, and 64 species in the Gulf of Alaska Unit, migrate to the San Juan Islands; Grays Harbor, Willapa Bay, and Columbia River estuaries, and the national wildlife refuges in Washington. See attached comment letter for full text of this comment.