Submission Number: MBTL-EIS-0002531 

Received: 11/17/2013 12:00:00 AM
Commenter: Alissa French

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: Alissa French []
Sent: Sunday, November 17, 2013 2:36 PM
Subject: Longview Scoping Comment

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

I am concerned about the likely inevitable economic and environmental impacts of a
large scale coal terminal moving 44 million tons of coal annually out of Longview, WA.

In the Joint Aquatic Resource Permit Application, the effect of the terminal on local
threatened species and critical habitat is touched upon, but in no way is it thoroughly
addressed. The current proposal is limited to information about critical habitat only in
the “vicinity of the project” – the area directly adjacent to the land to be used for the
shipping facility itself. It does not yet include critical habitat that will be crossed by
barges, ships and other project related transit; will be pressured by activity in areas
adjacent to said critical habitat areas; will be impacted by long term, large scale
environmental changes related to the transport and burning of coal in Asia; or will be
directly impacted by persons or vehicles in areas not directly adjacent to the land to be
use for the proposed terminal. Any critical habitat, including migration routes, spawning
grounds, etc located in the Columbia River, the banks of the Columbia, the Pacific
Ocean or any other area of land, water or air that is impacted in any way by the
proposed terminal in Longview must be considered within the scope of the project. Any
interaction with critical habitats that occurs as a direct result of a coal export terminal at
Longview needs to be studied and included in an EIS and the project proposal. These
impacts must include the proportionate effects of global warming, mercury
contamination and pollution arising from the burning of coal shipped from Longview
regardless of where it is burned. The scoping must include the effects of all vessels
regardless of size and including but not limited to tankers, barges, small boats,
refuelers, helicopters, aircraft, trucks, cars, and all related vehicles to the project. The
presence of additional persons, noise, pollution or other additional new elements in any
critical habitat area must be included in the scope. The proximity of open railroad cars
to the river (1,000 ft), must be scrutinized more closely and any introduction of coal dust
into the local ecosystems must be highly prioritized in any EIS related to the Longview
terminal. Any pressures put on critical habitat areas caused by animals, plants,
materials or activities being pushed out, added, stressed or augmented in areas
adjacent to said critical habitat areas must be studied and included in the scope of the
project. Any and all impacts on critical habitats, including those not directly adjacent to
the shipping facility itself, need to be avoided or fully mitigated if avoiding them should
prove impossible. No further harm to threatened species or their habitats can be

Simply because orcas do not swim up the Columbia River the some hundred miles to
the proposed terminal site does not mean that their critical habitat areas will not be
bisected by the paths of barges, tankers, ships, boats and other vessels. Their critical
habitat is also downstream from the proposed terminal, meaning all coal dust, diesel
particulate, chemicals, leaks, and other contamination will be carried directly toward
their critical habitats by the Columbia. These impacts must be considered in the scope
of the project, included in an EIS, addressed in the proposal and fully mitigated if a
permit is to be considered. Direct harm to orcas, salmon, sturgeon, trout, sea lions or
other threatened species by the proposed Longview Terminal given the current level of
scoping is entirely foreseeable. These populations are sensitive, highly valuable and
irreplaceable. As such, as harm to threatened species anywhere in the world as a
result of the aforementioned impacts including global climate change as a result of
carbon emissions must be fully studied, addressed and prevented by the applicant. It is
probably that many impacts, including those caused by climate change, coal dust and
related emissions will prove immitigable and will require some severe changes in the
methods used to transport coal at the very least.

As a citizen of Whatcom County, I rely on Lake Whatcom for clean drinking
water. Studies show that up to 30% of the mercury deposition in Lake Whatcom is a
direct result of coal being burned in Asia. The applicant must mitigate any future impact
on my right to clean drinking water if their permit application is to be considered. The
effect of burning the coal shipped from the Longview terminal on the drinking water in
Lake Whatcom must be included in the scope of this project, seriously addressed in an
EIS and fully studied and mitigated by Millennium Bulk. Any impact on the rights of
Whatcom County citizens and persons all around the world to clean drinking water is
absolutely unacceptable and should not only be included in the scope of the EIS, but
included at a high priority.

The current proposal for the coal terminal at Longview includes dredging a significant
proportion of the river bed to allow for the passage of barges. In the current JARPA,
350,000 cubic yards from an area of 48 acres is included in the dredge. The river bed
in this area is likely full of contaminants. Dredging this area would reintroduce many
toxic and harmful chemicals and substances into the river ecosystem. The material
removed during the dredge would also contain heavy metals and other toxins and will
likely require special treatment. The Weyerhaeuser complex and the
former Reynolds Aluminum smelter have doubtless introduced many hazardous
substances including but not limited to mercury, aluminum, fluoride, cryolite,
perfluorocarbons, lignin, transition metal compounds etc. Hydrogen fluorides are toxic
to vegetation. Perfluorocarbons gases are strong greenhouse gases with a long
lifetime. Aluminum smelting waste can be flammable and combustible. Any additional
risk for coal fires or explosions caused by residual chemicals already in the current site
or dredged up from the river bed must be studied, addressed in the EIS, mitigated and
explained in the permit proposal. Any impacts of dredging on the aforementioned
threatened species and critical habitats must be studied, included in the scope,
mitigated and address in any permit application.

It is likely that any materials dredged from the river bed in the amounts specified in the
JARPA will be hazardous to humans and will require special handling, treatment and
disposal. The applicant must research the potential impacts, plan for all eventualities
and ensure that no harm is incurred by any humans, plants, animals, habitats,
ecosystems, communities, economies or individuals. Any effects of dredging on the
river ecosystem, threatened populations, must be included in the scope. Any effects of
handling and disposal of materials resulting from the dredging must be studied, planned
for and included in the scope of the proposal.

If the river must be dredged repeatedly to ensure the functioning of the terminal, the
applicant must provide details about how frequently the dredges must occur, the volume
of material that must be dredge each time, the effects each dredging will have on the
river ecosystem, how the dredged material will be handled, where the dredged material
will be disposed of, any effects of dredging on the personnel responsible for the
dredging or disposal of said materials and any effects of disposing of the dredge
materials on the environment, ecosystem, communities and persons residing near
where the material is disposed of. Any harm incurred by the river ecosystem, the
personnel involved in the dredging and disposal and the ecosystem and community
near the disposal site must be mitigated by the applicant and addressed in the EIS,
proposal and application.

Dredging and skyrocketing river traffic may contribute to erosion, degradation and
pollution of the Columbia River drainage basin – an area roughly the size of
France. Any potential impacts on this area from any project related activities must be
included in the scope of the EIS and the permit application. Any critical habitat areas
adjacent to the drainage basin must be considered “in the vicinity of the project”.

Grain can be combustible when stored as it is at the current Longview shipping
facility. Coal is also combustible. Any potential interaction of the different materials
being shipped out of the Longview terminal must be included in the scope of the project
and the EIS. Coal dust is hazardous to humans if inhaled or consumed and causes and
myriad of medical problems including but not limited to neurological and cognitive
disorders like Alzheimer’s and cancer. Longview is also shipping a valuable food
resource and any and all contamination of the grain at Longview is unacceptable. The
foreseeable contamination of said grain by any contaminants related to the shipping of
coal including but not limited to coal dust, coal particles, diesel exhaust particulates, and
pollutants and contaminants unearthed while dredging the Columbia River. Any loss of
product incurred by the farmers and shippers of the grain would be fully the
responsibility of the applicant, Millennium Bulk. Any risks or hazards imposed on the
grain shipping facility by the proposed coal shipping facility must be acknowledged in
the scope of the project and addressed in the EIS and permit proposal.

A comment has already been submitted by the cities of Camas, Lacey, Livingston,
Olympia, and Vancouver and any economic impacts on these any communities
adjacent to areas used in relation to the proposed Longview coal terminal shipping
facility must be included in the scope of the EIS and application. Many communities
have a healthy water sport and tourism economy which would be damaged by
persistent barge traffic. Wind surfing, sailing, kayaking, swimming, and boating are all
important parts of river cities’ economies. Tourism to river side and sea side cities
might also be effected by an increase in water traffic and related pollution,
contamination, noise, transit delays, loss of natural beauty, any decrease in the
population of local wildlife, a perceived degradation of environmental values and clean
air and water. Any negative economic impact to these communities would have to be

The fishing industry of Washington State employs 66,000 people and is an incredibly
important asset in this time of high unemployment and economic crisis in the US. Any
negative impacts on the fishing industry are unacceptable and must be completely
mitigated by Millennium Bulk before a permit is considered. Any impacts on the key
species fished, including but not limited to impacts on other plant and animal species
that are part of the ecosystem in which key fish species exist; any harm or changes to
the geologic and geographic environment in which key species exist; any direct impact
to key species themselves; any change to the global climate in which key species exist
as a result of coal being transported to the proposed facility, shipped from the proposed
facility to buyers or burned anywhere after leaving the facility; any impact on the
success of fishing expeditions as a result of the increased shipping traffic leaving the
proposed terminal; any extra cost incurred by fisherman as a result of increased
shipping traffic leaving the proposed terminal; any impacts resulting from leaks,
emissions, dumps, residual dust and particulates, collisions, or sinking by any vessels
related to the proposed project; and any changes in any species breeding, migration,
feeding, or behavioral habits as a result of any activities related to the proposed terminal
must be fully reviewed and studied during an EIS and completely mitigated by the
applicant, Millennium Bulk. Any detrimental impacts to the Washington State fishing
industry are unacceptable and must be mitigated before a permit is to be considered.

The merits of this particular location must be researched in an EIS and defended in any
future project description of application. The proposed terminal is over 100 miles from
the coast and will require the use of extra and specialized vessels including flat bottom
barges and a facility to move cargo from the barges to cargo ships. The proposed site
is on the former site of an aluminum smelting plant – which has predictably left
combustible by-products which will increase the risk of fire or explosion of the coal and
contamination of the local ecosystem as a result of the required dredging. The
proposed site will share a facility with a grain shipping facility which will predictably be
contaminated or destroyed if any type of accident at all – small or large- should
occur. The proposed site may encroach on First Nation’s lands and any local native
populations must be engaged with and their concerns addressed before any application
is brought forward. The applicant, Millennium Bulk, must make a strong case for the
use of this particular area for their proposed coal shipping facility as supported by a full
and complete EIS before a permit application is to be considered. The proposed site
will bring loose coal and the result coal dust within 1,000 ft of the Columbia River,
immitigably contaminating the river ecosystem and, thus, the salmon and threatened
population, the fishing industry, and local economies.

I am also concerned that Millennium Bulk is inexperienced with the implementation of a
large scale shipping facility. The project description provided by SSA Marine for their
proposed Cherry Point terminal was in excess of 400 pages and reflected at least some
thought on a large scale. The initial JARPA provided by Millennium Bulk speaks to an
extremely narrow view of the scope of the project and a limited amount of thought
toward the full scale of the project. To include the full scope of the project, I would hope
that a much longer proposal is demanded and expected by the citizens and
communities affected.

Thank you for including these impacts in the EIS.


Alissa French