Submission Number: MBTL-EIS-0002368
Received: 11/19/2013 2:54:06 AM
Commenter: David Kershner
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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Dear Co-Lead Agency Representatives,
I am a resident of Lummi Island, which is less than 10 miles from the proposed Gateway Pacific Terminal (GPT) project at Cherry Point in Whatcom County. I am writing to urge you to include in the scope of the EIS for the Millennium Bulk Terminals (MBT) project an accurate assessment of the increase in train traffic that will be associated with this project and the cumulative rail corridor impacts of all coal export terminals currently proposed for Washington and Oregon. Without such an accurate assessment, it will be impossible to perform a valid assessment of significant impacts of the project.
Some proponents of the MBT project claim that the up to 44 million tons of coal proposed for shipment out of the MBT site will simply be shipped through Western Washington to Canadian ports if the project is not approved. This argument is simply not supported by the facts. Canadian ports are developing new capacity, but there is no evidence to suggest that more than 12.5 metric million tons of capacity at those ports will be available for US coal. By contrast, US coal companies is seeking approval for approximately 140 million metric tons of capacity for US coal at terminals or proposed terminals in Washington and Oregon.
In evaluating the impacts of increased train traffic on communities in Washington State, it is incumbent on the agencies to establish a valid baseline condition. Clearly, there will be a substantial increase in train traffic resulting from the MBT project, the human health, environmental, and economic impacts of which must the thoroughly analyzed.
As a result, I request that the agencies include within the scope of the EIS an analysis of the impacts of increased train traffic on communities along worst-case scenario rail routes.
For an analysis of the facts regarding Canadian port capacity, please see the attached report prepared by Sightline Institute (www.sightline.org/wp-content/uploads/.../canada-coal_2012.pdf).