Submission Number: MBTL-EIS-0002535 

Received: 11/15/2013 12:00:00 AM
Commenter: Christine S. Lehnertz
Organization: National Park Service

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
MBTL-EIS-0002535-59307.txt Size = 10 KB
Download Adobe Reader
Submission Text
From: PWR Regional Director, NPS []
Sent: Friday, November 15, 2013 2:10 PM
Cc: Allison O'Brien; NPS FOVA Superintendent; NPS LEWI Superintendent; NPS LECL Superintendent;
NPS WASO EQD ExtRev; Alan Schmierer
Subject: ER\13-0551 Comments Regarding the Proposed Millennium Bulk Coal Transfer Facility in
Longview, Washington


Pacific West Regional Office
333 Bush Street, Suite 500
San Francisco, California, 94104-2828

L7619 (PWR)

November 13, 2013

Danette L. Guy, Project Manager
U.S. Army Corps of Engineers
Seattle District, MBTL EIS Co-Lead Agencies
710 Second St., Ste.550
Seattle, WA 98104

Re: ER\13-0551 Comments Regarding the Proposed Millennium Bulk Coal Transfer
in Longview, Washington

Dear Ms. Guy:

The National Park Service (NPS) has reviewed the Notice of Intent for a joint Environmental Impact Statement, to be prepared by co-lead agencies U.S. Army Corps of Engineers, Cowlitz County, and Washington State Department of Ecology. The proposed Millennium Bulk Terminals-Longview (MBTL) project, located in the western Longview industrial area along the Columbia River, would handle coal from interior US. The MBTL would consist of two piers, conveyor, and access ramp on
190 acre portion of the 536 acre site. Both piers would connect onto shore via an 800 foot access trestle. The piers and trestle would support two ship loaders. MBTL would also dredge approximately 500,000 yards3 of substrate from a 48 acre berthing area along the riverward side of the proposed piers; this substrate would be disposed into the flow lane of the Columbia River.

Periodic future dredging to maintain the berthing area is included. The shipping facility would include a 75 acre open-air storage area serviced by an on-site balloon track system with parking capacity for eight trains. Rail-mounted reclaimers would convey coal from the storage area to the loading facility. The terminal would also include rail car unloading facilities, roadways, service buildings, storm water treatment facilities, and utility infrastructure.

Shipping and train activity in the area would increase if the MBTL project is
implemented. Approximately 38 acres of Columbia River waters and wetlands would be directly impacted, and downstream and upstream areas would be indirectly impacted. The NPS has concerns about the proposed MBTL project, since three units of the National Park System are located in the area of potential effect and could be directly or indirectly affected by project implementation. Our comments are as follows:

Fort Vancouver National Historic Site
Fort Vancouver National Historic Site is located on the Columbia River in Vancouver, Clark County, Washington. It encompasses 209 acres and contains numerous cultural resources associated with American Indians, the Hudson’s Bay Company colonial establishment, and the first U.S. Army post in the Pacific Northwest. The Burlington Northern-Santa Fe (BNSF) Railroad runs through the National Historic Site and a portion of the lines are on an easement that dates back to 1906 when the original Spokane, Portland, and Seattle (SP&S) Line was built across the U.S. Army post. During World War I, Sitka spruce was brought from the Coast Range, including areas of Olympic National Park, by railroad to be milled on the grounds of the National Park unit into aviation-grade lumber to support the war effort. The affiliated sites of the Vancouver National Historic Reserve include the
City of Vancouver’s Old Apple Tree Park, where the region’s oldest living survivor of the early colonial days of Fort Vancouver still lives. There are numerous archaeological resources associated with Fort Vancouver National Historic Site including the Fort Vancouver Village (“Kanaka” Village) and associated pond and waterfront complex, and underwater sites within the Columbia River (the
Quartermaster East and Benoit sites). The entire area is a listed National Register District. Today, over one million visitors come to the park and its affiliated sites each year to learn more about the history of the Pacific Northwest region. The park unit and its affiliated sites are important historic properties.

The EIS should include analysis to address the potential for the proposed MBTL to adversely affect Fort Vancouver National Historic Site and its affiliated areas of the Vancouver National Historic Reserve. In particular, we are concerned regarding the increased rail traffic associated with the estimated 3,000 unit trains annually (over 8 per day) bringing up to 44 million metric tons of coal through the park to the facility in Longview, Washington. This increased rail traffic could have direct and indirect effects on the historic properties of Fort Vancouver National Historic Site. Increased rail traffic may increase the risk of a derailment that could damage irreplaceable cultural resources, and could pose hazards to visitors enjoying the site. For example, some of the areas immediately adjacent to the railroad contain highly sensitive and significant subsurface archaeological resources associated with the colonial period of the Pacific Northwest. A derailment in these areas could directly damage or destroy these resources. The EIS should include analysis to address the
increased risk of a derailment, or other accident, and how contingency plans would minimize harm of derailment on the fragile and significant cultural resources of the National Park System unit. Any accident could endanger visitors that are using the waterfront, Old Apple Tree Park, or the Confluence Project Land Bridge. Analysis of increased risk to human health associated with the trains within this unit of the National Park System should accompany the EIS.

We are concerned that the increased rail traffic from the proposed MBTL could introduce visual and audible elements that might diminish the ability of visitors (including American Indians and Native Hawaiians) to make connections to the historic properties of the district, including in particular aspects of feeling and setting. Views from inside and adjacent to the Fort, Village, and Waterfront
Complex may be disrupted, affecting the ability of the visitor to orient to the historical context of the site. Some of these sites may have a special significance to American Indian tribes. The increased rail noise will be a constant distraction that could further diminish the integrity of the setting and feeling of the Fort, Village, and Waterfront. Analysis in the EIS should address indirect effects associated with the increased rail traffic through this unit of the National Park System and its
affiliated areas.

Last, given other rail-based projects planned for the area, it is likely that there will be cumulative effects associated with this project that may adversely affect the National Park Service unit and its affiliated areas. Analysis in the EIS should address the cumulative effects associated with this project in light of other major projects planned for the area and the existing rail traffic.

Lewis and Clark National Historical Park and Lewis and Clark National Historic Trail

In addition to the foreseeable increase in fugitive dust from rail line activity, the EIS should analyze the effects of the export terminal due to increased ship traffic on aquatic habitats and wildlife in the  Columbia River, including the potential for shipping accidents resulting in coal and/or fuel spills. In addition to Fort Vancouver NHS, other units of the National Park System with potentially affected  shorelines and watersheds along the Columbia River are Lewis and Clark National Historic Trail (NHT) and Lewis and Clark National Historical Park (NHP), each having sites in Oregon and Washington. The ecological integrity and associated human values of these parks are directly and indirectly linked to the overall health of the Columbia River. The NPS is concerned that coal export could adversely impact the health of these waterways in several interrelated ways.

Potential impacts to anadromous fish species such as salmon and steelhead should be evaluated because these species are vital to the regional economy as well as being fundamental resources at Lewis and Clark NHP. Visitor experience and the extant historic scene at both the NHP and NHT could also be adversely affected, and avoidance or mitigation strategies should be developed.

Thank you for the opportunity to provide comments concerning recognition and protection of these  units of the National Park System for consideration in preparing the Draft EIS. For additional  information, or any clarification about our comments, our contacts are as follows:

Fort Vancouver NHS – Superintendent Tracy Fortmann, 612 East Reserve Street, Vancouver WA
(360) 816-6205

Lewis and Clark NHP – Superintendent Scott Tucker, 92343 Fort Clatsop Road, Astoria OR 97103
(503) 861-4401

Lewis and Clark NHT – Superintendent Dan Wiley, 601 Riverfront Drive, Omaha NE 68102 (402) 661-


/s/ Christine Lehnertz
(signed original on file)

Christine S. Lehnertz
Regional Director, Pacific West Region

OEPC–REC Allison_O’
FOVA – Supt