Submission Number: MBTL-SEPA-DEIS-0003352 

Received: 6/13/2016 9:28:57 PM
Commenter: Donald Collins
Organization: Western Research Institute
State: Wyoming

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments: No Attachments
Submission Text
It is important to note that the Department of Energy (DOE) 2015 Annual Energy Outlook (AEO2015) used for the SEPA Draft Environmental Impact Statement (DEIS) does not include the greenhouse gas emission reductions and climate change benefits for deploying carbon capture utilization and storage (CCUS) technologies on coal power plants likely to use coal exported from the Proposed Action. Likewise, AEO2015 analyses do not include CCUS technology benefits within the United States. In addition, the DOE 2016 International Energy Outlook (IEO2016) also does not include the greenhouse gas emission reductions and climate change benefits for deploying CCUS technologies on coal power plants likely to use coal exports from the Proposed Action. This important omission in the DOE AEO2015 and IEO2016 results in the DOE overstating the global annual greenhouse gas emissions during the operational time period for the Proposed Action. Furthermore, use of the DOE AEO2015 for the SEPA DEIS also results in overstating the likely greenhouse gas emissions and climate change impacts for the Proposed Action, and therefore incorrectly finds that the Proposed Action constitutes an “Unavoidable and Significant Adverse Environmental Impact”.