Submission Number: MBTL-EIS-0003080 

Received: 11/14/2013 10:34:00 AM
Commenter: Leo Mitchell

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 Sent:Thursday, November 14, 2013 10:34 AM Subject:Support for Longview/EIS comment

Thank you for the opportunity to submit a comment regarding the scoping for Millennium Bulk Terminals coal export facility. I strongly support the environmental study and the thousands of jobs this project will create.

The scoping decision should limit the analysis of impacts in the EIS to those impacts that have a close connection to the project. Impacts that have a superseding cause to an impact can be identified, but should not be studied to the same degree as impacts that are proximately caused by the project. For instance, because the proposal is a terminal proposal, the use of the bulk commodity by a third party is a superseding and intervening cause to the combustion of coal. As a result of these superseding causes, the construction and operation of the terminal is not a proximate cause of the combustion of coal. If a close causal relationship cannot be established for emissions, the impacts should only be accounted for as part of the No Action Alternative as an impact that would have occurred without the project and studied nonetheless in the cumulative impact section of the EIS as a non-project impact, if studied at all.

The growing worldwide trade market needs an accessible, dependable, and conscientious facility to conduct business. I appreciate the planning Millennium Bulk Terminals has exhibited in its proposal for the project in Longview and wish to thank the agencies for its consideration in moving this project forward.

Sincerely, Leo Mitchell