Submission Number: MBTL-EIS-0003129 

Received: 11/13/2013 4:32:00 PM
Commenter: david stalnaker

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:Wednesday, November 13, 2013 4:32 PM Subject:EIS - Millennium

Millennium Bulk Terminals has proposed a coal export terminal at Longview that is both environmentally-sound and economically beneficial. I ask that you approve this project and the environmental study without delay.

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 co-lead agencies are presenting an excellent scoping process. I urge them to proceed promptly with a Draft Environmental Impact Statement that allows Millennium Bulk Terminals to become one step closer to building, hiring, and exporting. Under this scenario good paying jobs will come to a community in need. Not only will the local but the regional economy will reap the benefits. Please do the right thing and make this project a reality.

Sincerely,david stalnaker david stalnaker