Submission Number: MBTL-SEPA-DEIS-0002444
Received: 6/10/2016 11:39:39 AM
Commenter: Lisa Lowy
Organization: City of Livingston Montana
Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
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This letter is being written in response to the Millennium Bulk Terminal EIS released for Public Comment on April 29, 2016. Upon review of the Draft Document it was noted that the operational and environmental impacts focused primarily on the regional impacts in Washington State and did not adequately address the down rail impacts to other areas, specifically those in Montana. Coal originating out of the Power River Basin Mines will travel the majority of the main rail lines through Montana and specifically through our community in Livingston.
Based on the outline in the EIS, the construction of this terminal and the ensuing increases in rail traffic would essentially double the rail traffic Livingston currently experiences. Our community has several unique characteristics which create extraordinary challenges for an increase of traffic on this magnitude. They are:
1. Our community is bisected by rail lines with only 1 grade separated crossings and two at grade crossings. We already suffer significant bottle necks in the flow of our local traffic due to rail traffic which at times can have all at grade crossings blocked leaving only one alternative route.
2. Additionally, loaded rail cars (especially heavier loads such as coal) require additional pusher engines in order to get over the Bozeman Pass which gains significant elevation upon exiting Livingston. Coupling and uncoupling these additional engines, which all occurs in our downtown railyard, would create further delays that would significantly impact traffic flow as well as impede the ability of emergency services to access the North side of our community. Additional air pollution related to the increased operations and added idling time of the engines presents additional quality of life and environmental impacts to our community.
3. Our community additionally has safety concerns for pedestrian traffic with increases of this magnitude in our community. All of the safe route to schools utilized by our children and families from the North side of our community require the crossing of operating tracks.
It is our hope that as the Public Comment period concludes, sufficient evidence and concern will be raised and acknowledged so that the down rail impacts to Montana and specifically in Livingston as well as an adequate plan to mitigate those impacts can be developed as part of the final EIS for this project. Thank you very much for your consideration of our concerns as it pertains to this EIS and we are available to discuss any of the items further.
A formal letter will follow via US Mail.
Interim City Manager
Chairman, Livingston City Commission