Submission Number: MBTL-SEPA-DEIS-0000658 

Received: 5/21/2016 6:35:47 PM
Commenter: Jean Avwery
State: Washington

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
Submission Text
Please deny permits for the Millennium Bulk coal-export terminal. I am concerned about excessive greenhouse gas emissions as well as weak and unenforceable mitigation. The draft EIS states that: • S-40: [even] 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. • S-40: 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-43: Greenhouse gas emissions attributable to the Proposed Action would occur from construction, operation, transportation and changes in coal and natural gas usage. The greenhouse gas emissions attributable to the Proposed Action would be reduced but not entirely eliminated by implementing the proposed mitigation measures related to fuel efficient equipment, anti-idling policies, and a mitigation plan. The Proposed Action’s remaining projected increase in greenhouse gas emissions would still be significant and adverse [see also S-39]. • S-38: Under the preferred 2015 Energy Policy scenario, the change in [greenhouse gas] emissions, or the net annual emissions, from the Proposed Action in 2028 would be 3.2 million metric tons of CO2e. This is equivalent to adding about 672,100 passenger cars on the road each year. • S-38 and 39: The total net emissions for the preferred 2015 Energy Policy scenario from 2018 to 2038…would exceed various thresholds that are proposed in federal and state regulations and guidance. • S-39: Since the net greenhouse gas emissions attributable to the Proposed Action in the preferred scenario would exceed these standards, the emissions are considered to be significant impacts. The climate change impacts resulting from this increase to greenhouse gases would persist for a long period of time, beyond the analysis period, and would be considered permanent. The climate change impacts, while global in nature, would affect Washington State. Based on these considerations, emissions attributable to operations of the Proposed Action under the 2015 Energy Policy Scenario are considered adverse and significant… . Implementation of proposed mitigation measures (Table S-2) to develop a mitigation plan, reduce emissions, and improve efficiencies would reduce but not eliminate the greenhouse gas emissions attributable to the Proposed Action. The Proposed Action’s remaining projected greenhouse gas emissions would be significant and unavoidable…[see also S-430). Please think of the long-term consequences of this proposed coal terminal, and deny the permits.