Submission Number: MBTL-EIS-0003311 

Received: 11/9/2013 1:58:00 PM
Commenter: William Bigelow

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:Friends of the Columbia Gorge <> on behalf of William Bigelow <> Sent:Saturday, November 09, 2013 1:59 PM To:Placido, Elaine Subject:Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk Terminals Longview LLC Coal Export Terminal

Nov 9, 2013

Director Elaine Placido 207 4th Ave. N. Kelso, WA 98626

Dear Director Placido,

Please accept these scoping comments for the environmental impact statement for the Millennium Bulk Terminal (MBTL) proposal for Longview, WA.

The Army Corps of Engineers has a poor track record when it comes to coal. In Appalachia, the Corps of Engineers has enabled hugely destructive mountaintop removal at every turn. So I am skeptical that they can be trusted when it comes to protecting the Pacific Northwest. We shall see.

In deciding the scope of an Environmental Impact Statement, you must take into account all the factors highlighted by the Friends of the Columbia River Gorge:

The most significant of these: Climate change: Coal-burning power plants are the primary source greenhouse gases driving global climate change. The MBTL project would discourage alternative energy development and prolong addiction to coal -- and accelerate climate change. Greenhouse gas emissions from the mining, transportation and burning of coal must be analyzed in the EIS.

Indian Treaty Rights: The Yakama and other tribes believe that coal is a threat to treaty rights, which should be paramount in deciding whether to permit coal to invade their lands and waterways.

National Scenic Area Impacts: The Columbia River Gorge is designated as a National Scenic Area under federal law. This law requires protection and enhancement of scenic, natural, cultural and recreation resources and air quality. The impacts of transporting coal through the Columbia River Gorge, a protected National Scenic Area, must be analyzed.

Air Quality Impacts: Air Quality in the Gorge is already degraded. Increased coal train traffic would worsen air quality and visibility. The human health and the environmental impacts of diesel emissions and coal dust from up to 18 trains per day must be analyzed. Coal pollution is already a problem in the Gorge from just a few coal trains per week, with large amounts of coal polluting Gorge lands and waterways.

Water Quality: Adverse effects of coal spilling into waterways in the Gorge from open-top coal cars must be analyzed and avoided.

Transportation: Additional trains will block at-grade crossings in the Gorge, interfering with commerce, recreation, tourism and emergency services.

New track construction: Existing rail traffic in the Gorge is near capacity. Approval of the MBTL project would result in the need to expand rail capacity in the Gorge with new tracks and sidings. Rail lines in the Gorge follow the Columbia River and cross many tributaries and wetlands. Impacts from the construction of new tracks would cause adverse effects to water quality, fish, wildlife and plant habitat. These impacts must be analyzed and avoided.

Train-caused fires: Train-caused fires are a regular occurrence within the Columbia Gorge, resulting in damage to native plants, sensitive wildlife habitat and property. Increased train traffic and transporting coal in open containers would exacerbate the problem. Increased risk of fire from coal trains must be analyzed in the EIS.

Cumulative effects: There are three pending proposals for coal exports in the Pacific Northwest. All would transport coal from the Powder River Basin through the Columbia River Gorge to export facilities. The combined impacts of past, present, and reasonably foreseeable uses and developments must be thoroughly explored in the EIS.

Area-wide EIS: The Army Corps of Engineers should refrain from making a decision on any permits until an area-wide EIS is completed to analyze the impacts of all three coal export proposals in the Pacific Northwest.


Mr. William Bigelow 2814 NE Mason St Portland, OR 97211-7112 (503) 282-6848