Submission Number: MBTL-SEPA-DEIS-0003329 

Received: 6/13/2016 8:55:26 PM
Commenter: Brenda Lindlief-Hall
Organization: National Wildlife Federation
State: Montana

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
Submission Text
On behalf of the National Wildlife Federation, thank you for this opportunity to comment on the April 29, 2016 Millennium Bulk Terminal draft environmental impact statement. We hereby voice opposition to the proposed Millennium Bulk Terminal (MBT) coal export facility and ask that the co-lead agencies, Cowlitz County and the Washington State Department of Ecology that prepared the draft environmental impact statement (EIS) choose the No Action Alternative. The proposed Millennium Bulk Terminal (MBT) coal export facility would lead to unprecedented rail traffic across Wyoming, Montana, Idaho and Washington. Approximately sixteen uncovered coal trains would cut through critical wildlife habitat and pass through scenic rail corridors and parallel sensitive waterways. Despite the unprecedented, wide-ranging impacts of MBT, the EIS fails to fully address the cumulative impacts. The impacts of the proposed MBT are not confined to the Longview port, but extend from the mines in the Powder River Basin, along the full length of the rail lines to the port at Longview, across the Pacific Ocean, and beyond to Asia where the coal would ultimately be burned. But the impacts do not stop there. The impacts of green house gases from burning coal overseas come full circle back to pollute our air and our wildlife and aquatic life habitat, and create ever-increasing climate change threats. Despite these well-known cumulative impacts, the EIS addresses only the immediate impacts of MBT. Coal mining occurs on some of the most fragile lands and most important wildlife habitat in the Powder River Basin. Both direct and indirect mining impacts, from strip mining and blasting to sedimentation and pollution of waterways, threaten aquatic and wildlife habitat. In addition, the failure to fully reclaim the land after mining, or to reclaim to substandard conditions, is well documented and leaves the land unable to sustain healthy wildlife populations. Coal trains leave hundreds of pounds of fugitive coal dust in their wake en route from the mines in the Powder River Basin to the ports on the west coast, fouling our waters and threatening our already stressed aquatic life, fisheries and fishing and sporting economies across the northwest. Fugitive coal dust not only contains particulates that pollute the air, but deposits mercury, lead, arsenic and other neurotoxins and carcinogens into the air, land and water. Coal dust smothers and reduces oxygen in waterways that is essential to healthy aquatic life populations, and those devastating impacts cascade up the food chain. In addition to the on-the-ground impacts, burning fossil fuels and the attendant greenhouse gas emissions likewise threaten our fish and wildlife and way of life due to climate change. Pollution and climate impacts from burning coal knows no boundaries, and poses unacceptable, potentially catastrophic, risks to wildlife and aquatic life. It is our understanding that Washington statutes and regulations provide the co-lead agencies with the authority to deny a project if such denial is based on an appropriate policy; if the agencies find that the project would result in significant adverse impacts; and if the adverse impacts of the project cannot be mitigated through reasonable mitigation measures. We do not think there are any mitigation measures available to remedy the adverse impacts that would unfold should MBT permit be granted. It is our position that Cowlitz County and the Washington State Department of Ecology have more than ample authority to deny the MBT permit. We ask that you say no to this disastrous proposal and choose the no action alternative.