Submission Number: MBTL-EIS-0002469 

Received: 11/19/2013 1:26:00 AM
Commenter: Kevin Weitemier
Organization: Native Plant Society of Oregon
State: Oregon

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
Submission Text
From: Kevin Weitemier <>
Sent: Tuesday, November 19, 2013 1:26 AM
Subject: Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk
Terminals Longview LLC Coal Export Terminal
Nov 19, 2013

US Army Corps of Engineers, Cowlitz County, Washington Department of Ecology WA

Dear Washington Department of Ecology,

Please accept these scoping comments for the environmental impact statement for the Millennium Bulk
Terminal (MBTL) proposal for Longview, WA.

The Native Plant Society of Oregon would like to ensure that the impacts of the proposed Millennium
Bulk Terminal and increased coal transport along the length of the associated coal routes are considered
in a full Environmental Impact Statement, with particular attention paid to the impact on vegetation
communities, particularly in the Columbia River Gorge. This Environmental Impact Statement should be
completed before the issuing of any permits is considered.

Coal dust has been shown to have several significant effects on both abiotic conditions and floral
communities in eastern Oregon ecosystems.
Specifically, deposition of coal dust has been shown to significantly increase soil temperature, lower pH,
and alter soil moisture regimes.
Additionally, there are indications of increased levels of iron, copper, zinc, sulfates, and lead on soils
with dust accumulation (Spencer 1997, 2001).

Deposition of coal dust has been shown to alter floral communities:
Lichen communities are significantly altered and many species, including those that fix nitrogen, are
significantly less frequent on soils with coal dust relative to those without. An increase in the moss
Ceratodon purpureus on soils with coal dust suggests that increased levels of metals in the soil may be
driving vegetation change. Coal dust depositions may be altering vascular plant phenology. Communities
with coal dust exhibited earlier germination and flowering of annuals and some perennials, and
communities with dust tended to have a lower biomass of native perennials (Spencer 1997, 2001).

Finally, if coal trains increase the risk of train-caused fires, the impacts of these fires on local vegetation
must be assessed.

While these effects should be considered for all vegetation along the coal routes and in the Columbia
River Gorge, it is particularly important for rare plants in the Gorge including, but not limited to:
Penstemon barrettiae, Sullivantia oregana, Cimicifuga elata, Ranunculus recondis, Agrostis howellii,
Rotala ramosior, Fritillaria camschatcensis, Corydalis aquae-gelidae, Carex macrochaeta, Erigeron
howellii, and Artemisia campestris var. wormskioldii.

Thank you for your consideration,

Native Plant Society of Oregon
c/o Kevin Weitemier, M.S.
NPSO Scientific Advisor on coal issues

*Spencer, Sherry, and Robert Tinnin. 1997. Effects of coal dust on plant growth and species composition
in an arid environment. Journal of Arid Environments. 37: 475-485.

*Spencer, Sherry. 2001. Effects of coal dust on species composition of mosses and lichens in an arid
environment. Journal of Arid Environments. 49: 843-853.


Mr. Kevin Weitemier
2120 NW Harrison Blvd
Apt 1
Corvallis, OR 97330-5571