Submission Number: MBTL-SEPA-DEIS-0002560 

Received: 6/12/2016 8:19:56 PM
Commenter: James Chase
State: Oregon

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
Submission Text
Learn From Cherry Point The Corps of Engineers denied permits for a nearly identical terminal at Cherry point because of harm anticipated for the fish and because such harm likely violated treaty rights with the Lummi Tribe. The same harm will result to fish in the Columbia River and likely violate treaty rights with the Confederated Tribes of Warm Springs, the Yakimas and others. How can you possibly reach a different conclusion for the Millennium Terminal. This alone should give you cause to deny the permits. Violation of the Clean Water Act Coal dust from the 2-3 trains per day currently running through the Columbia River Gorge already violates standards for the Clean Water Act. An additional 16 trains per day (full + empty) would take this pollution to a disastrous level. I am sure you are aware that a coalition for opponents to the terminal have brought suit against BNSF and Arch Coal for violation of the Act. I have seen the evidence and it is overwhelming. The suit has stood through several challenges by the defendants, and a victory for the plaintiffs seems likely. You should at least review the evidence in this case and include it in your analysis. If the plaintiffs win, you will look incompetent or corrupt should you recommend approval of the permits without even having considered this evidence. Market for Coal Is Declining The market for coal is declining worldwide. Even the worst polluters like China have realized that they must go in other directions for energy. The coal companies are all teetering on the brink of bankruptcy. It is irresponsible to allow Longview and the State of Washington to spend significant funds and make large, long-range commitments to a company and an industry that may very well cease to exist in the future. It has happened before as with the Port of Portland in the 1980’s. Deny the permits for Millennium and help Longview pursue other opportunities with better chances for success. A Terrible Partner At the recent comment hearing in Cowlitz County much was said about Millennium as a safety-conscious, good-paying, responsible employer. I don’t know if that is true or not, but I do know that anyone would have to be crazy to get into a business relationship with a company like Arch Coal (or whatever they are called now). They are in bankruptcy. You should deny the permits on that basis alone! Leave It in the Ground! The facts are that the US and the rest of the world do not need the coal today, or are at least heading rapidly in that direction. However, the day may well come when future generations will have no choice and will need it – perhaps at a time when better technology will exist for extracting and burning coal cleanly and when the world is ready to pay the price for burning coal cleanly. We should leave it in the ground for future generations and not rush to squander it at ridiculously low prices for a short-term profit. Risk of Transportation Disaster in the Gorge. The Columbia River Gorge is a scenic and recreational wonderland and an agritourism and geotourism powerhouse, but is fragile. The recent derailment and explosions in Mosier OR of a train carrying Bakken Crude have been considered a “wake up” call for the dangers of such trains. However, the fact is that many of us have been “awake” for a long time about these risks. It was never a question of “if”, but only “when and where”. A derailment and spill of coal into the river will happen and the results will be devastation. Neither the risk of derailment nor the consequences can be mitigated. Do not allow our National Treasure of the Columbia Gorge to be ruined forever. Deny the permits. What Will Jay Do? You might want to think about that! If he fails to deny the permits, Governor Inslee will be dead politically. Deservedly the same fate would flow to you! You could take the cowardly way out and recommend granting the permits, and just anticipate denial by the Governor. Or you could become far-sighted heroes and recommend denial of the permits. Deny the permits for your own security and peace of mind! The Scope Is Far too Narrow! Consider just one aspect – jobs. Much has been said about the jobs to be generated for terminal workers and railroad employees. However, if you also consider the job losses for employees in restaurants, hotels, recreational activities, and so forth in the Gorge that will result from the pollution from the coal trains, the job tally will be a net loss. Consider all aspects of employment before baking a decision of the permits. Third Party Indemnification I have to carry liability on my car despite 56 years of driving – without an accident. The cost of remediation of a major spill of coal into the Columbia could easily reach into the billions of dollars. You should require that order of magnitude of liability insurance as a pre-condition of any granting of permits. Many Flaws, but Enough Facts for Denial The Draft EIS has many gaping flaws – in scope, in the data, in some of the logic, in so many areas. However, despite this the Draft concludes that there is a broad range of unavoidable adverse impacts. End of story! You could do much more, but what you have done already provides sufficient cause for denial of the permits. Bring this madness to an end! Comments Submitted by the Friends of the Columbia Gorge, letter of June 13. Very complete! Very well done! I support them and agree with them in every respect!