Subject: NWP-2012-56 Coyote Island Coal Export Terminal; DSL APP0049123, Coyote Island Terminal LLC Removal-Fill Permit Application
Dear Director Louise Solliday and Mr. Steve Gagnon,
I am writing to urge you to do everything in your power to ensure that the Army Corps of Engineers conduct a full environmental review, pursuant to the National Environmental Policy Act ("NEPA"), for the first coal export terminal in Oregon--Ambre Energy's Coyote Island Terminal, LLC proposal. In addition, the Oregon Department of State Lands (DSL) should deny the removal-fill permit for this project because it fails to meet the requirements of state law.
The opening of coal export terminals in Oregon and Washington is among the more pressing environmental and energy issues of our time. There are multiple proposed terminals in the region currently under review or in exploration stages. Collectively, these projects could transform the region with toxic pollution, traffic and rail congestion, habitat destruction, and a dramatic increase in greenhouse gas emissions. Individually, the projects will also have significant impacts, including in-water risks to protected species and pollution to nearby communities.
Preparation of an EIS and consideration of alternatives is required by federal law and, more importantly, necessary to ensure that the public understands the environmental risks and has an opportunity to weigh in. To ensure this review accounts for the significant cumulative impacts of multiple proposed Northwest coal export terminals, the Corps must first prepare a Programmatic Environmental Impact Statement that carefully analyzes the combined impacts of multiple, similar coal export terminal proposals. The Programmatic EIS must be completed before the Corps issues an individual EIS for Ambre's Port of Morrow proposal.
DSL must also take action to protect the public and Columbia River from the serious threats posed by Ambre's proposed terminal. There is no public need for this project, and the costs far outweigh any alleged benefits. In turn, DSL should deny the project's removal-fill permit. The project will negatively impact threatened and endangered species and their designated critical habitat, interfere with recreational and tribal fishing, and transform the region with rail congestion. Thank you for considering my comments.
