Submission Number: MBTL-EIS-0002911 

Received: 11/19/2013 12:36:00 AM
Commenter: John Tuxill
Organization: 
State: 

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:John Tuxill <johntuxill@yahoo.com> Sent:Tuesday, November 19, 2013 12:16 AM To:comments@millenniumbulkeiswa.gov Subject:Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk Terminals Longview LLC Coal Export Terminal

Dear U.S. Army Corps of Engineers, WA Department of Ecology, and Cowlitz County Commission,

Dear Agency Review Team:

I am a Washington state resident living at 1604 20th St., Bellingham, WA. I am a husband, and a father to two young boys. I am a professional scientist, a recreational fisherman and crabber, a botanist, a birdwatcher, and I spend my free time outdoors whenever possible. In short, I care deeply about the environment, economy, and quality of life in Washington state.

I believe that the scale and substance of the proposed Millennium Bulk Terminals Longview LLC Coal Export Terminal carry far-reaching consequences for all residents of the state of Washington. I regard a detailed, comprehensive, and thorough Environmental Impact Statement (EIS) at a scale commensurate with the scale of the Millennium Bulk Terminals Longview LLC Coal Export Terminal (i.e. regional and global as well as local) to be of the utmost importance. I respectfully request that the EIS please address, in a programmatic fashion, the following impacts on the natural and human environment, and possible mitigation requirements:

1) Please determine the total amount of CO2 and black soot emissions that would result from the mining, transport by rail, export by cargo ship, and burning of millions of tons of coal exported annually through the port. U.S. demand for coal is forecast to remain steady or decline slightly for the foreseeable future, so one cannot argue that the coal exported through Longview would be burned anyway whether or not the Millennium Bulk Terminals Longview LLC Coal Export Terminal is built. Instead, the coal-related emissions would be a direct, specific, and non-duplicable result of building and operating the Export Terminal. They must be considered in the EIS for it to be credible.

Accordingly, please study how the resulting CO2 and black soot emissions will impact and accelerate climate changes in Washington state. Please study the emission-related impacts on ocean acidification patterns affecting marine ecosystems and shellfish; on the future status of glaciers in Washington state; and on snowmelt and rainfall contributing to river and stream flows, particularly summer flows that are crucial to salmon populations and agriculture. Please include projections for extreme weather events in Washington (e.g. drought, landslides and flooding from high rainfall events) that climate modeling suggests may increase due to increasing greenhouse gas emissions.

Please assess how CO2 and black soot emissions from the Millennium Bulk Terminals Longview LLC Coal Export Terminal will offset the goals established by Washington State to reduce greenhouse gas emissions as adopted by our state legislature in 2008. "Washington State adopted greenhouse gas reduction standards via legislation adopted in 2008. (RCW 70.235.070(1)(a). The statute establishes that by 2020, emissions shall be reduced to 1990 levels. By 2035, GHG emissions are to be 25 percent below 1990 levels and by 2050, they are to be 50 percent below 1990 levels." (James Wells, Don't Pee In The Pool!, January 5, 2013)

2) Please evaluate the environmental and health impacts from the mercury and other pollutants that would result from burning the millions of tons of coal exported annually through the Millennium Bulk Terminals Longview LLC Coal Terminal. Pollutants produced by burning coal in Asia are known to be transported in the atmosphere across the Pacific Ocean, and have a measurable negative impact on the air quality and environmental health of Washington state. Please model and assess the cumulative impacts of all known pollutants subject to long-distance transport that would result from burning the millions of tons of coal that would be exported annually through the Millennium Bulk Coal Export Terminal.

3) Please also study and model the diesel particulate pollution that would result from locomotives and ships transporting coal through our region to and from the Millennium Bulk Terminals Longview LLC Coal Export Terminal. I specifically request that you determine how many excess deaths and hospitalizations would be expected in Washington state from diesel particulate matter from Coal Export Terminal- related diesel locomotive and ship traffic. Please include comparisons of baseline and expected rates of asthma, cancer, stroke, and heart attack.

4) Please conduct a thorough, comprehensive, vessel traffic study that addresses the increased environmental risks associated with the ship traffic generated by the Millennium Bulk Terminals Longview LLC Coal Export Terminal along the full North Pacific route to Asia. The long-distance movements of fish stocks, marine mammal populations, and ocean currents clearly demonstrate that the North Pacific Ocean is an integrated ecosystem. For the vessel traffic study to be credible and meaningful, it must address environmental impacts and risks not just in Washington state, but also in Canadian and Alaskan waters.

Accordingly, please study the increased risk of collision, allison, or grounding of all vessels while navigating shipping lanes along the Washington Coast. Please identify the measures that would be needed to reduce the risks to vessels, shorelines, and public safety from shipping accidents. Please evaluate the increased risk and consequences to the economy, wildlife, and the environment by any oil or cargo spill near or along the Lower Columbia River and the Washington coast. Please assess the economic consequences of increased ship traffic and oil spill on the shellfish, tourism, recreational boating and fishing industries along the Lower Columbia River and the Washington Coast. Please study the harmful effects on marine mammals of mechanical and surface sound propagation along the Washington Coast that would result from increased ship traffic associated with the Millennium Bulk Terminals Longview LLC Coal Export Terminal. Please also assess the increased potential for vessel strike to marine birds and mammal species due to the ship traffic associated with Millennium Bulk Terminals Longview LLC Coal Export Terminal.

Please also assess the environmental risks of larger and greater numbers of ships using Unimak Pass, Alaska, along the great circle route to Asia. Please include evaluation of the environmental consequences of being unable to contain an oil spill along the more remote British Columbia and Alaskan coasts along the great circle route.

5) Please address the potential environmental impacts of coal dust (i.e. "fugitive coal particles") that would escape from the Millennium Bulk Terminals Longview LLC Coal Export Terminal via wind transport while in storage at the site. Coal dust contains a number of carcinogenic and neurotoxic compounds, including mercury, lead, cadmium, and polycyclic aromatic hydrocarbons. Please address how such contaminants are likely to impact riverine and estuarine food webs, including salmon populations, sturgeon populations, riverine bird populations, and riverine mammal populations.

6) Please address the potential environmental and human health impacts of fugitive coal particles (both dust and chunks) that escape from rail cars while in transit to Millennium Bulk Terminals Longview LLC Coal Export Terminal from coal mine sources in Montana and Wyoming. Please include study of how other trains using the same tracks moving at higher speed might disperse the fugitive coal particles that originate from Millenium Terminal train traffic.

7) Please study the environmental impacts of the water withdrawals that will be needed to maintain the dust and fire suppression system for the coal that will be piled and stored at Millennium Bulk Terminals Longview LLC Coal Export Terminal.

I believe that my concerns expressed here accurately reflect how the potential impacts of the Millennium Bulk Terminals Longview LLC Coal Export Terminal proposal will unfold at regional and global scales as well as locally. I would like to reiterate my firm opinion that the EIS must similarly examine impacts at region and global scales. I find it nothing short of a dereliction of duty that the Army Corps of Engineers to date has not taken a comprehensive, programmatic approach to their review of environmental impacts of the Millenium Terminal and other coal export facility proposals around the Pacific Northwest-an essential step to ensuring a credible environmental impact review.

Thank you for taking my above comments into consideration, and I look forward to seeing the results of the scoping process.

Sincerely,

John Tuxill, PhD 1604 20th St. Bellingham, WA 98225

John Tuxill 1604 20th St Bellingham, WA 98225 360-393-3796