Submission Number: MBTL-SEPA-DEIS-0000374
Received: 5/16/2016 12:34:50 AM
Commenter: William Brake
Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
I am William Brake a retired Energy Engineer and Registered Professional Engineer and have reviewed the MBTL SEPA DEIS and I support the “No Action Alternative”
Proposed mitigation measures are outlined in Table S-2. If the proposed mitigation measures were implemented, impacts would be reduced but would not completely eliminate significant adverse environmental impacts resulting from construction and operation of the Proposed Action. Unavoidable and significant adverse environmental impacts could remain for nine environmental resource areas: social and community resources; cultural resources; tribal resources; rail transportation; rail safety; vehicle transportation; vessel transportation; noise and vibration; and greenhouse gas emissions.
S.7.1 Social and Community Resources
Implementation of the Proposed Action would increase rail traffic that would increase noise levels along the Reynolds Lead and BNSF Spur in Cowlitz County. The increased noise levels from 16 trips per day related to the Proposed Action would expose noise–sensitive receptors to moderate and severe noise impacts per applicable criteria. These noise impacts would occur in areas with minority and low-income populations; therefore, the Proposed Action would have a disproportionately high and adverse effect on minority and low-income populations. If the mitigation measure to implement a Quiet Zone is approved, it would eliminate the need for trains related to the Proposed Action to sound horns as they approach the at-grade crossings, and it would eliminate the potential disproportionately high and adverse effect on minority and low-income populations. However, without approval and implementation of a Quiet Zone, the Proposed Action’s disproportionately high and adverse effect on minority and low-income populations would be unavoidable.
The disproportionate high and adverse effects on the minority and low income populations is unacceptable. With current rail traffic at one train per week to a projected 16 trains per week or more is impacting their rights.
The Facility Siting Guidelines of the American Institute of Chemical Engineers would not choose this location just because there is 190 acres of industrial land adjacent to the Columbia River. The location should typically be 5 to 10 miles from any urban setting to minimize neighborhood conflicts.
The executive management team of MBTL should be required to live in the housing adjacent to the proposed facility as they are on call 24/7/365.
Thank you for allowing public comment on the MBTL SEPA DEIS.
William Brake PE