Comments for Application APP0049123
(Applicant: Coyote Island Terminal, LLC)


NAME: Shawn Zumwalt
EMAIL: shawn.zumwalt@dsl.state.or.us
COMMENTS:
-- No Proprietary Issues.

Appears to be outside of our ownership which is the Original OHWE aproximately 230'elevation mark.
NAME: Tony Justus
CITY: Pendleton
STATE: OR
AGENCY: OWRD
COMMENTS:
-- No comment.

Does not appear to be any water used in the project.
NAME: Fran Recht
CITY: Depoe Bay
STATE: OR
AGENCY: public
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

This is a major activity and requires and EA or an EIS, especially with the number of already threatened and endangered species; a removal fill application is premature and incomplete with a thorough environmental analysis. An EIS or EA would address topics that are inadequately or not address in this application which are necessary to make an informed decision on this application including: individual impacts and cumulative impacts of more fill in the river system, pile driving, impacts of ship traffic noise, pollution, shading (by the ships at the docks and of the docks themselves, the impacts on the State's commitment to reduce greenhouse gases ( which exporting overseas doesn't escape), increased truck traffic, rail traffic, impacts on tribal and sport fishing users of the river.

I am opposed to the granting of this permit and recommend that the permit be denied
NAME: Laurie Dougherty
CITY: Salem
STATE: OR
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

Oregon is renowned as a leader in clean energy and environmentally responsible practices. For Oregon to facilitate the export of coal to Asia dishonors that legacy. From mining to transport to burning, coal leaves a trail of dust, emissions and toxic residues that pollute land, air and water; contribute to climate change; and harm human health and the health of other species. Oregon should not be a pathway for coal. Please reject the permit for the Coyote Island Terminal. Thank you.
NAME: Deborah Hazen
CITY: Clatskanie
STATE: OR
AGENCY: The Clatskanie Chief
COMMENTS:
-- Morrow Pacific permit required.
-- No adverse effects expected.

Coal
Editorial Comments in The Clatskanie Chief (March 22, 2010)
by Deborah Steele Hazen
Representatives of Ambre Energy’s Morrow Pacific project have been actively presenting information to community leaders and the public about the proposed project which includes the Pacific Transloading LLC operation at the Port Westward industrial site near Clatskanie.
Presentations were made two weeks ago to the Clatskanie city council, and Monday to the Rainier city council. Reports have also been made to the Scappoose city council, Columbia City council, the Columbia County Economic Development Team, the Clatskanie Kiwanis Club, Rainier Chamber of Commerce and Vernonia school board. Upcoming presentations are planned for the Vernonia and St. Helens city councils.
At a well-attended Port of St. Helens meeting held in Clatskanie Jan. 25, the five-member Port commission voted unanimously to “approve entering into a terminal services agreement option with Ambre and Pacific Transloading LLC to operate a coal transloading facility at the existing dock at Port Westward.”
If the project becomes a reality, the coal will be brought by enclosed barges from the Port of Morrow on the Columbia River at Boardman to the Port Westward dock, located on the Columbia at what was once the Beaver Army ammunition depot, and will be transloaded into the holds of Panamax ships. Panamax ships are ships that can go through the Panama canal.
Once it leaves the Port of Morrow, and until it reaches its final destination in Japan, South Korea or Taiwan, the coal will be completely enclosed and never see the light of day.
There is so little impact to the air and water in Oregon, that the Oregon Department of Environmental Quality is not requiring any permits for the project.
The U.S. Army Corps of Engineers will be looking at the project in regard to in-water work in the Columbia River for the barge loading facility at the Port of Morrow in Board. On the Port Westward end, the completely enclosed transloading equipment will be installed on the existing dock.
The coal will be shipped to Boardman by train from the Powder River Basin in southeastern Montana and northeastern Wyoming to an enclosed transfer and loading facility at the Port of Morrow on the Columbia River about 160 miles east of Portland.
There has been a lot of talk by those who oppose the use of coal for any purpose, about dust from trains. Modern coal producers and shippers use various means to prevent the loss of coal during shipment, including sealants and using train cars built so as not to sift coal dust.
At any rate, studies show that the vast majority of dust that does escape from coal trains does so in the first 100 miles or so. That would be somewhere in the middle of Montana or Wyoming.
Coal trains travel virtually every day up the I-5 corridor from Vancouver through Kelso to the coal-fired plant at Chehalis, and farther north to British Columbia, which currently has the only Pacific coast coal export facilities.
There is not a coal dust problem in the I-5 corridor. At least, not one that we’ve ever heard of.
The coal destined for the proposed Ambre Energy Pacific Transloading facility at Port Westward will be taken off trains over 200 miles east of here at Boardman, and loaded, through a completely-enclosed system onto completely-enclosed barges, hopefully built in Oregon, which will be towed down the river by tugboats - hopefully built in Oregon - to Port Westward.
There the coal will never see the light of day. It will be transloaded from the completely-enclosed barge, through a completely-enclosed conveyor loading system into the completely-enclosed holds of ships.
The operation will create an estimated 25 good-paying jobs here, many of them for local union longshoremen; another 25 jobs in Boardman at the Port of Morrow, and another 55 family-wage jobs in the transport of the coal from the Powder River Basin to Boardman, and then on the barges and tugs from Boardman to Clatskanie.
Coal, Jobs, Taxes
There are those who argue that it is wrong for the United States to export coal to the Pacific Rim countries. The fact is that the Pacific Rim countries are going to use coal. If they don’t buy our relatively clean coal, they will buy it from someplace else, and the sulfur emissions into the atmosphere will be worse.
We have heard opponents use the argument that we should save our coal reserves for the United States and not export them.
The fact is that the U.S. has the world’s largest reserve of coal. We have enough coal to continue to export coal to our trade allies in Europe, South America and Asia and to leave sufficient reserves for use in the country.
The United States has 28 percent of the world’s coal reserves, a larger share than any other country. The U.S. Energy Information Administration estimates that the U.S. has 261 billion short tons of recoverable coal reserves, which include only accessible coal that can be mined with today’s mining technology. This is estimated to be only 54 percent of the demonstrated reserve base, which could be accessed in the future.
Based on U.S. coal consumption for 2010, the U.S. recoverable coal reserves represent enough coal to last an estimated 249 years.
The fact is that Powder River Basin coal is already going to Asia, via trains going into Canada. We just don’t see the moral high ground in sending jobs that could be in the Pacific Northwest to Canada.
Exports and trade have always been important to the economy of the Pacific Northwest, and they are very important factors to recovery from this recession.
And, then there’s the taxes that this project would pay to help our county and special districts provide the services we need.
If it comes to fruition, the Morrow Pacific Project will pay about $750,000 in property taxes annually to both Columbia County and Morrow County. Additionally, it will pay about $850,000 in port fees to be used for more economic development.
Although it would be eligible for enterprise zone tax exemptions for this project, Ambre Energy is asking for none. Additionally it has pledged to pay 10 cents per ton of coal shipped - $350,000 per year based on the proposed initial 3.5 million tons per year - to Columbia County schools.
Each school district’s share of that would fund most of a teacher’s position. If the project grows to eight million tons per year, which is possible with the permission of the Port of St. Helens, that would mean $800,000 for the schools.
It seems to us that Ambre Energy has done everything it can to design this proposal - and we are talking about this specific proposal to bring coal to Port Westward by barge and transfer it out by ship - to meet Oregon’s strict environmental standards and sensitivities, and to be a good neighbor in the communities in which it is located.
We join Clatskanie Mayor Diane Pohl in supporting this project, and encouraging our readers to return the card that was sent to local residents in the mail or to visit www.MorrowPacific.com.
Trains are Coming
The other coal-related project that has been proposed for Port Westward, the Kinder-Morgan proposal, is entirely separate from the Ambre Energy Morrow Pacific project, and is still very much in the phase of assessing its feasibility.
If it came to pass, it would bring coal trains through Columbia County, and we understand that raises many concerns to which we are not insensitive.
The fact is that we have a rail line running through our county. It has been there since 1898. Decades ago, it had much more traffic than it had in the closing years of the 20th century and the beginning of the 21st.
But we have seen a rebounding of rail use for industrial transport in northwestern Oregon in the last few years, and we believe rail traffic is going to grow more, like it or not, coal or no coal. Projects in Clatsop County as well as Columbia County are being proposed that would use the railroad.
Rather than sitting by the tracks hoping more trains won’t come, we need to be seriously looking at how we can address legitimate concerns, so that the people of northwest Oregon can have both economic development and retain the livability of our communities.



NAME: Deborah Hazen
CITY: Clatskanie
STATE: OR
AGENCY: The Clatskanie Chief
COMMENTS:
-- Morrow Pacific permit required.
-- No adverse effects expected.

Coal
Editorial Comments in The Clatskanie Chief (March 22, 2010)
by Deborah Steele Hazen
Representatives of Ambre Energy’s Morrow Pacific project have been actively presenting information to community leaders and the public about the proposed project which includes the Pacific Transloading LLC operation at the Port Westward industrial site near Clatskanie.
Presentations were made two weeks ago to the Clatskanie city council, and Monday to the Rainier city council. Reports have also been made to the Scappoose city council, Columbia City council, the Columbia County Economic Development Team, the Clatskanie Kiwanis Club, Rainier Chamber of Commerce and Vernonia school board. Upcoming presentations are planned for the Vernonia and St. Helens city councils.
At a well-attended Port of St. Helens meeting held in Clatskanie Jan. 25, the five-member Port commission voted unanimously to “approve entering into a terminal services agreement option with Ambre and Pacific Transloading LLC to operate a coal transloading facility at the existing dock at Port Westward.”
If the project becomes a reality, the coal will be brought by enclosed barges from the Port of Morrow on the Columbia River at Boardman to the Port Westward dock, located on the Columbia at what was once the Beaver Army ammunition depot, and will be transloaded into the holds of Panamax ships. Panamax ships are ships that can go through the Panama canal.
Once it leaves the Port of Morrow, and until it reaches its final destination in Japan, South Korea or Taiwan, the coal will be completely enclosed and never see the light of day.
There is so little impact to the air and water in Oregon, that the Oregon Department of Environmental Quality is not requiring any permits for the project.
The U.S. Army Corps of Engineers will be looking at the project in regard to in-water work in the Columbia River for the barge loading facility at the Port of Morrow in Board. On the Port Westward end, the completely enclosed transloading equipment will be installed on the existing dock.
The coal will be shipped to Boardman by train from the Powder River Basin in southeastern Montana and northeastern Wyoming to an enclosed transfer and loading facility at the Port of Morrow on the Columbia River about 160 miles east of Portland.
There has been a lot of talk by those who oppose the use of coal for any purpose, about dust from trains. Modern coal producers and shippers use various means to prevent the loss of coal during shipment, including sealants and using train cars built so as not to sift coal dust.
At any rate, studies show that the vast majority of dust that does escape from coal trains does so in the first 100 miles or so. That would be somewhere in the middle of Montana or Wyoming.
Coal trains travel virtually every day up the I-5 corridor from Vancouver through Kelso to the coal-fired plant at Chehalis, and farther north to British Columbia, which currently has the only Pacific coast coal export facilities.
There is not a coal dust problem in the I-5 corridor. At least, not one that we’ve ever heard of.
The coal destined for the proposed Ambre Energy Pacific Transloading facility at Port Westward will be taken off trains over 200 miles east of here at Boardman, and loaded, through a completely-enclosed system onto completely-enclosed barges, hopefully built in Oregon, which will be towed down the river by tugboats - hopefully built in Oregon - to Port Westward.
There the coal will never see the light of day. It will be transloaded from the completely-enclosed barge, through a completely-enclosed conveyor loading system into the completely-enclosed holds of ships.
The operation will create an estimated 25 good-paying jobs here, many of them for local union longshoremen; another 25 jobs in Boardman at the Port of Morrow, and another 55 family-wage jobs in the transport of the coal from the Powder River Basin to Boardman, and then on the barges and tugs from Boardman to Clatskanie.
Coal, Jobs, Taxes
There are those who argue that it is wrong for the United States to export coal to the Pacific Rim countries. The fact is that the Pacific Rim countries are going to use coal. If they don’t buy our relatively clean coal, they will buy it from someplace else, and the sulfur emissions into the atmosphere will be worse.
We have heard opponents use the argument that we should save our coal reserves for the United States and not export them.
The fact is that the U.S. has the world’s largest reserve of coal. We have enough coal to continue to export coal to our trade allies in Europe, South America and Asia and to leave sufficient reserves for use in the country.
The United States has 28 percent of the world’s coal reserves, a larger share than any other country. The U.S. Energy Information Administration estimates that the U.S. has 261 billion short tons of recoverable coal reserves, which include only accessible coal that can be mined with today’s mining technology. This is estimated to be only 54 percent of the demonstrated reserve base, which could be accessed in the future.
Based on U.S. coal consumption for 2010, the U.S. recoverable coal reserves represent enough coal to last an estimated 249 years.
The fact is that Powder River Basin coal is already going to Asia, via trains going into Canada. We just don’t see the moral high ground in sending jobs that could be in the Pacific Northwest to Canada.
Exports and trade have always been important to the economy of the Pacific Northwest, and they are very important factors to recovery from this recession.
And, then there’s the taxes that this project would pay to help our county and special districts provide the services we need.
If it comes to fruition, the Morrow Pacific Project will pay about $750,000 in property taxes annually to both Columbia County and Morrow County. Additionally, it will pay about $850,000 in port fees to be used for more economic development.
Although it would be eligible for enterprise zone tax exemptions for this project, Ambre Energy is asking for none. Additionally it has pledged to pay 10 cents per ton of coal shipped - $350,000 per year based on the proposed initial 3.5 million tons per year - to Columbia County schools.
Each school district’s share of that would fund most of a teacher’s position. If the project grows to eight million tons per year, which is possible with the permission of the Port of St. Helens, that would mean $800,000 for the schools.
It seems to us that Ambre Energy has done everything it can to design this proposal - and we are talking about this specific proposal to bring coal to Port Westward by barge and transfer it out by ship - to meet Oregon’s strict environmental standards and sensitivities, and to be a good neighbor in the communities in which it is located.
We join Clatskanie Mayor Diane Pohl in supporting this project, and encouraging our readers to return the card that was sent to local residents in the mail or to visit www.MorrowPacific.com.
Trains are Coming
The other coal-related project that has been proposed for Port Westward, the Kinder-Morgan proposal, is entirely separate from the Ambre Energy Morrow Pacific project, and is still very much in the phase of assessing its feasibility.
If it came to pass, it would bring coal trains through Columbia County, and we understand that raises many concerns to which we are not insensitive.
The fact is that we have a rail line running through our county. It has been there since 1898. Decades ago, it had much more traffic than it had in the closing years of the 20th century and the beginning of the 21st.
But we have seen a rebounding of rail use for industrial transport in northwestern Oregon in the last few years, and we believe rail traffic is going to grow more, like it or not, coal or no coal. Projects in Clatsop County as well as Columbia County are being proposed that would use the railroad.
Rather than sitting by the tracks hoping more trains won’t come, we need to be seriously looking at how we can address legitimate concerns, so that the people of northwest Oregon can have both economic development and retain the livability of our communities.



NAME: Jerry M Healy
CITY: Heppner
STATE: OR
AGENCY:
COMMENTS:
-- No adverse effects expected.

I recommend that this permit be approved. I urge the Department of State Lands to authorize the Removal Fill Permit and allow the Morrow Pacific/Coyote Island terminal project to move forward. This project will benefit the community at large creating much need jobs, paying significant property taxes and supporting schools. These public benefits will be obtained while operating at or above Oregon's enviromental rules. This project will not adversely impact water resources nor interfer with public recreation, fishing or navigation.

I have reviewed the Morrow Pacific project and believe the covered/enclosed facilities will make this the most enviormentally friendly coal facility in the west.

I encourage you to bring family wage jobs back to the US while maintaining high enviormental standards protecting the waters of the Columbia River and clean air of eastern Oregon.
Thank You -- Jerry M Healy
NAME: Diane Wolfe
CITY: Boardman
STATE: OR
AGENCY: Boardman Chamber of Commerce
COMMENTS:

On behalf of the Boardman Chamber of Commerce, I am writing to urge the Department of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. We strongly believe that the Morrow Pacific project will benefit our community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer, Ambre Energy, has demonstrated a commitment to protecting Oregon’s air and water quality as well as fish and wildlife habitat at every stage of the proposed project. This project is being designed so as to not adversely impact water resources or interfere with navigation, fishing, and/or public recreation.

We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which will look similar to grain or food-processing facilities found today in Morrow County; and enclosed conveyors will transfer the coal to covered barges built specifically for this project.

Today we have an opportunity to bring family-wage jobs to Morrow County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Department of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.

NAME: Gerald Breazeale
CITY: Irrigon
STATE: OR
AGENCY:
COMMENTS:
-- No adverse effects expected.

The project is not much different from any other terminal installation. There are strict controls in place to ensure that the use of this facility will not degrade the environment.
NAME: Gary Neal
CITY: Boardman
STATE: OR
AGENCY: Port of Morow
COMMENTS:
-- No adverse effects expected.

On behaf of the Port of Morrow, I am encouraging the Department of State Lands to issue the removal fill permit to the Morrow-Pacific project so this important project can proceed. The family wage jobs this project will bring to our County is much needed especially in rural parts of our State.
This facility will operate in a manner that is consistent with Oregon's strong Environmental standards. Amber Energy has demonstrated it's commitment in protecting Oregon's air and water quality as well as fish habitat and environment at every stage of the project. Morrow Pacific's deign for storing and transferring coal far exceed standard practices to eliminate dust and spillage. Rail cars will be offloaded from an enclosed facility and the coal will be inside a covered building so no coal will be visible at the site. The facilities will look similar to other buildings in the industrial park. As coal is loaded into the barges the conveyors will be covered as well and the barges will have a lid on them to be enclosed and not visible. We have an opportunity to bring good family wage jobs to Morrow County in a way that meets Oregon's high standards of doing business here. We strongly encourage Department of State Lands to approve the removal-fill permit for The Morrow Pacific project and allow this project to move forward.

Sincerely
Gary Neal
NAME: Karen Pettigrew
CITY: Boardman
STATE: OR
AGENCY: City of Boardman, Oregon
COMMENTS:
-- No adverse effects expected.

On behalf of the City of Boardman, I am writitng to urge the Dept. of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. The project developer, Amber Energy, has demonstrated a commitment to protecting Oregon's air and water quality as well as fish and wildfile habitat at every stage of the proposed project.

I think it is important in this general economy to be pro-active in creating family wage jobs,property taxes and school support in Morrow County, Oregon and the USA.
NAME: Gary Neal
CITY: Boardman
STATE: OR
AGENCY: Port of Morow
COMMENTS:
-- No adverse effects expected.

On behaf of the Port of Morrow, I am encouraging the Department of State Lands to issue the removal fill permit to the Morrow-Pacific project so this important project can proceed. The family wage jobs this project will bring to our County is much needed especially in rural parts of our State.
This facility will operate in a manner that is consistent with Oregon's strong Environmental standards. Amber Energy has demonstrated it's commitment in protecting Oregon's air and water quality as well as fish habitat and environment at every stage of the project. Morrow Pacific's deign for storing and transferring coal far exceed standard practices to eliminate dust and spillage. Rail cars will be offloaded from an enclosed facility and the coal will be inside a covered building so no coal will be visible at the site. The facilities will look similar to other buildings in the industrial park. As coal is loaded into the barges the conveyors will be covered as well and the barges will have a lid on them to be enclosed and not visible. We have an opportunity to bring good family wage jobs to Morrow County in a way that meets Oregon's high standards of doing business here. We strongly encourage Department of State Lands to approve the removal-fill permit for The Morrow Pacific project and allow this project to move forward.

Sincerely
Gary Neal
NAME: Sheryll Bates
CITY: Heppner
STATE: OR
AGENCY: Heppner Chamber of Commerce
COMMENTS:
-- No adverse effects expected.

On behalf of Heppner Chamber of Commerce, I am writing to urge the Department of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. We strongly believe that the Morrow Pacific project will benefit our community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer, Ambre Energy, has demonstrated a commitment to protecting Oregon’s air and water quality as well as fish and wildlife habitat at every stage of the proposed project. This project is being designed so as to not adversely impact water resources or interfere with navigation, fishing, and/or public recreation.

We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which will look similar to grain or food-processing facilities found today in Morrow County; and enclosed conveyors will transfer the coal to covered barges built specifically for this project.

Today we have an opportunity to bring family-wage jobs to Morrow County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Department of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.

NAME: Michael Blauer
CITY: Heppner
STATE: OR
AGENCY: Willow Creek Valley Economic Develoment Group
COMMENTS:
-- No adverse effects expected.

On behalf of Willow Creek Valley Economic
Development Group, I am writing to urge the Department of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. We strongly believe that the Morrow Pacific project will benefit our community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer, Ambre Energy, has demonstrated a commitment to protecting Oregon’s air and water quality as well as fish and wildlife habitat at every stage of the proposed project. This project is being designed so as to not adversely impact water resources or interfere with navigation, fishing, and/or public recreation.

We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which will look similar to grain or food-processing facilities found today in Morrow County; and enclosed conveyors will transfer the coal to covered barges built specifically for this project.

Today we have an opportunity to bring family-wage jobs to Morrow County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Department of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.

NAME: Debbie Pedro
CITY: Hermiston
STATE: OR
AGENCY: Hermiston Chamber of Commerce
COMMENTS:
-- No adverse effects expected.

Division of State Lands

March 30, 2012

On behalf of the Greater Hermiston Chamber of Commerce Board of Directors and our members, I am writing to urge the Division of State Lands to authorize the Removal Fill Permit and Allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward.

On March 22, 2012 the Morrow Pacific project was presented and The Hermiston Chamber of Commerce Board of Directors voted unanimously to support the project.

We strongly believe that the Morrow Pacific project will not only benefit Morrow County, but also provide significant economic and social benefit to the residents and business in Hermiston’s community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer Ambre Energy has demonstrated a commitment to protecting Oregon’s air and water quality and fish and wildlife habitat at every stage of the proposed project.

We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which looks similar to grain or food-processing facilities found today in Morrow County. And enclosed conveyors will transfer the coal to covered barges, built specifically for this project.

Today we have an opportunity to bring family-wage jobs to Morrow and Umatilla County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Division of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.


Sincerely,

Debbie Pedro
Executive Director Greater Hermiston Chamber of Commerce


NAME: Kim B. Puzey
CITY: Umatilla
STATE: OR
AGENCY: Port of Umatilla
COMMENTS:
-- No adverse effects expected.

On behalf of the Port of Umatilla, I am writing to urge the Department of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. We strongly believe that the Morrow Pacific project will benefit our community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer, Ambre Energy, has demonstrated a commitment to protecting Oregon’s air and water quality as well as fish and wildlife habitat at every stage of the proposed project. This project is being designed so as to not adversely impact water resources or interfere with navigation, fishing, and/or public recreation.

We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which will look similar to grain or food-processing facilities found today in Morrow County; and enclosed conveyors will transfer the coal to covered barges built specifically for this project.

Today we have an opportunity to bring family-wage jobs to Morrow County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Department of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.

NAME: Jeff Bailey
CITY: Heppner
STATE: OR
AGENCY: Bank of Eastern Oregon
COMMENTS:
-- No adverse effects expected.

I am writing to urge the Department of State Lands to authorize the Removal Fill Permit and allow Coyote Island Terminal, LLC, and their Morrow Pacific project to move forward. We strongly believe that the Morrow Pacific project will benefit our community while operating in a manner that’s consistent with Oregon’s strong environmental standards. In addition to creating jobs, supporting schools and generating significant property taxes and port revenues for Morrow County, the project developer, Ambre Energy, has demonstrated a commitment to protecting Oregon’s air and water quality as well as fish and wildlife habitat at every stage of the proposed project. This project is being designed so as to not adversely impact water resources or interfere with navigation, fishing, and/or public recreation.



We’ve reviewed the Morrow Pacific project proposal and designs and are confident that the proven processes used to store and transfer coal at the Port of Morrow will go beyond standard practices to eliminate dust and spillage. For example, railcars will be unloaded in a completely enclosed storage facility. No coal will be visible from outside the facility, which will look similar to grain or food-processing facilities found today in Morrow County; and enclosed conveyors will transfer the coal to covered barges built specifically for this project.



Today we have an opportunity to bring family-wage jobs to Morrow County, and we can do it in a way that meets Oregon’s high standards for doing business here. We strongly encourage the Department of State Lands to approve the Removal Fill permit and allow the Morrow Pacific project to move forward.

NAME: Bill Duke
CITY: Pendleton
STATE: OR
AGENCY: Oregon Department of Fish and Wildlife
COMMENTS:
-- Advise change to design or methodology.

The Oregon Department of Fish and Wildlife recommends including the following conditions in the final permit issued for this project.
• A detailed fish salvage plan shall be submitted to the Oregon Department of Fish and Wildlife and approved prior to implementation of construction activities.
• All work shall be completed within the Oregon Department of Fish and Wildlife preferred work window of December 1 to March 31.
• Vibratory hammers shall be used for pile driving to the greatest extent possible.
• Bubble curtains shall be used for all impact pile driving to reduce potential noise impacts to fish.
• All piling shall be fitted with devices to prevent perching by piscivorus birds.

NAME: Gregory Sotir
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

As a homeowner in Oregon I ask that this permit be denied. Shipping large quantities of coal down the Columbia Gorge for export and combustion in Asia will accentuate CO2 and sulphur emissions that will negatively affect my health, the local bioregion due to increased mercury contamination, and the larger planetary biosystem.

As the holders of the Oregonian peoples land and water trust, I ask you to represent the people of Oregon and protect them from this potentially catastrophic eventuality by denying Ambre Energy the leasing of Coyote Island Terminal for coal transport and export.
NAME: Lori Damiano
CITY: Portland
STATE: OR
AGENCY: n/a
COMMENTS:
-- Recommend permit denial.

I am a resident of Kenton and am very sensitive to the air quality. I currently experience debilitating headaches when the air quality is poor. I am very concerned about the impact the export station would have on my health and the health of my community. Please deny this permit!

Thank you,
Lori Damiano
NAME: Carole Most
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

The proposed fill or removal DOES NOT conform to sound policies of conservation and WILL interfere with public health and safety.
NAME: Leon Laptook
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

The proposed fill or removal DOES NOT conform to sound policies of conservation and WILL interfere with public health and safety.
NAME: Iris Sea
CITY: Salem
STATE: OR
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.

Imposing the dust, noise, traffic interference upon the city of Salem and it's population is forcing a
negative situation upon our freedom from harm and
peace. Either revise or omit the entire project.
NAME: Thomas James Dee
CITY: Portland
STATE: OR
AGENCY: Oregon Resident
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to water resources.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

Nowhere in the Environmental Review or the Joint Permit Application is there a Compensatory Wetland Mitigation plan that addresses the Principal Objectives set forth in the Oregon Administrative Rules. There do not appear to be approved wetland delineations for the Port of Morrow or the Port Westward sites. The only maps of wetlands and non-wetland waters are the National Wetland Inventory Maps presented in Figures 3.11-1 and 3.11-2. An approved wetland delineation should be submitted before this permit is approved.
NAME: Lynette Yetter
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

Whether in the wake of mining in Montana's Powder River basin, in communities bisected by coal trains, in port towns facing massive coal export terminals, or abroad in villages displaced by new coal-fired power plants, coal anywhere is unhealthy everywhere.

NAME: Leslie Moore
CITY: Hailey
STATE: ID
AGENCY:
COMMENTS:
-- Recommend permit denial.

The future is not in coal.
NAME: Jerry Bruce McConoughey
CITY: Portland
STATE: OR
AGENCY: self
COMMENTS:
-- Recommend permit denial.

Global warming is accelerating at an alarming rate causing rising sea levels and climate destabilization. Coal is the leading cause of the warming. Also China is so polluted from coal emissions that Chinese who can afford to are leaving the country. China is trying to cut back on coal burning. The U.S. and Oregon should not be caught at the short end of this stick. Let's not be fooled by desperate coal companies. Let's do what's right for the earth's atmosphere.
NAME: Corrine Lindsay
CITY: Lexington
STATE: OR
AGENCY: Lindsay Ranch
COMMENTS:
-- No adverse effects expected.

I live in sight of the Carty Coal plant and there has never been any
coal dust in all the years Carty has operated. I support the transshipment of coal as it is proposed in a completely closed system.
NAME: Chad D. Eckard
CITY: Spring Grove
STATE: PA
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

the compensatory mitigation is insufficient to compensate for the reasonably expected adverse impacts of the project and I recommend the permit should be denied.
NAME: Paula Surmann
CITY: Beaverton
STATE: OR
AGENCY: Private Citizen
COMMENTS:
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Recommend permit denial.

Coal is dirty from the moment it's dug out of the earth to the moment it's burned. Global climate change will be made worse by this project. Short-term gain for long-term pain is NOT worth it. Thank you for considering my comments.
NAME: joy waltermire
CITY: Shelton
STATE: WA
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

In regards to the Coal Export Terminal being permitted on the Columbia River the compensatory mitigation is insufficient to compensate for the reasonably expected adverse impacts of the project and I recommend the permit should be denied.
NAME: Paul Barnett
CITY: Fresno
STATE: CA
AGENCY:
COMMENTS:
-- Recommend permit denial.

One cannot undo the beauty of nature and ever hope to return it to its original glory. I ask that the project not be approved.
NAME: Michelle Minshall
CITY: Seattle
STATE: WA
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.


NAME: Dennis McVicker
CITY: Vancouver
STATE: WA
AGENCY: Tidewater
COMMENTS:
-- 49123 permit required.
-- No adverse effects expected.

This letter is in response to the DSL's request for public comment on the above referenced permit application. Tidewater is a barge transportation and terminal company that operates on the Columbia & Snake River system and we support the approval of the DSL permit application #49123 for the Coyote Island Terminal dock at the Port of Morrow. The proposed dock and associated project, if approved, will provide a much-needed benefit to Oregon’s economy.

In 2007, Tidewater Barge Lines, Inc. obtained a permit to construct a similar dock, for barge loading of biofuels, which is 900 feet upstream from Coyote Island’s proposed dock. The permit obtained by Tidewater allowed for construction of a dock with an access ramp, series of pile supports and connecting structure, four pipelines with support structure and three moorage dolphins, similar to what is being proposed by Coyote Island Terminal.

Our dock was constructed with minimal environmental impact. We used steel grating that lends to light penetration of the water; steel plates under equipment during construction to protect the shoreline; constrained pile driving to one month (March 2007) as called for under ODFW’s in-water work period for the area; and complied with the terms and conditions of the Endangered Species Act and the Magnuson-Stevens Fishery Conservation and Management Act.

Building this dock delivered a beneficial asset for river commerce in the Pacific Northwest, supporting economic activity along the river while respecting the environment, aquatic wildlife and habitat. Coyote Island’s proposed dock will achieve the same balance of creating new economic opportunities for the region while respecting the critical role the river plays in our environment.

As a barge transportation operator on the Columbia River, we welcome increased commerce to this river system. Commercial users, recreationists, and fishermen have historically coexisted with the levels of traffic proposed by this project. In fact, increased river commerce enables the U.S. Army Corps of Engineers, ports, and other river groups to leverage additional funds for maintenance and upkeep of the river system, benefiting the overall economy of the Pacific Northwest.

We encourage the DSL to approve the Coyote Island Terminal dock application. The project represents an opportunity to benefit Oregon’s economy with an environmentally respectful and responsible approach.
NAME: Suzette Kamm
CITY: Portland
STATE: OR
AGENCY: Coyote Island Terminal LLC
COMMENTS:

Please deny the application submited by Coyote Island Terminal LLC application number: App0049123

DSL Coordinator Redon Charles
NAME: Susan Sherman
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

Transporting coal right past my neighborhood can have no good effects...
NAME: William A. Furman
CITY: Lake Oswego
STATE: OR
AGENCY: The Greenbrier Companies, Inc.
COMMENTS:
-- 49123 permit required.
-- No adverse effects expected.

I am writing to offer my support for the Coyote Island Terminal Application (#49123). Ambre Energy's Coyote Island Terminal dock and the associated Morrow Pacific project demonstrate that a healthy environment and economic opportunity can go hand in hand. The dock proposed by Coyote Island Terminal at the Port of Morrow clearly meets DSL requirements.

The Morrow Pacific project has committed to working with local companies to ensure the economic benefit stays in our state. Manufacturing jobs are critical to our economy and for over 90 years Gunderson has been a major employer in our state. These jobs are family-wage and offer competitive benefits.

Morrow Pacific has signed a letter of understanding with our company, Gunderson, for the construction of 15 enclosed barges, valued at over $50 million. This would employ 350 workers full-time with benefits for two years.

We need projects like the Morrow Pacific project – that demonstrate an ability to meet environmental standards and contribute to our local economy.

I urge the Department of State Lands to approve the application.





NAME: Chet Phillips, Mayor
CITY: Boardman
STATE: OR
AGENCY: City of Boardman
COMMENTS:
-- 49123 permit required.
-- No adverse effects expected.

As members of the City Council of Boardman, Oregon, we are writing to urge the Oregon Department of State Lands to approve Coyote Island Terminal’s Application (#49123) and support the associated Morrow Pacific Project. The proposed project clearly demonstrates that environmental stewardship and economic opportunity can go hand in hand.

Oregon's rural counties have been hard hit in recent years and the economic recovery has been slow in coming to communities such as ours. But the Morrow Pacific project could dramatically change all of this. The project will bring much-needed economic development to the area while protecting the Oregon we know and love.

The project could bring an estimated 25 family-wage jobs to Morrow County, plus make a voluntary annual contribution to local schools, $350,000 a year at initial capacity of 3.5 million metric tons per year. In addition, the project could also generate over $1.5 million per year in property taxes. Such an economic stimulus would have a tremendous impact on our community by supporting schools, businesses and our community's way of life.

For these reasons, we strongly encourage the Oregon Department of State Lands to approve the Morrow Pacific project.

NAME: Chuck Little
CITY: Hermiston
STATE: OR
AGENCY: Pendleton Building & Construction Trades Council
COMMENTS:
-- #49123 permit required.
-- No adverse effects expected.

On behalf of thr Pendleton Building & Construction Trades Council, I urge the Oregon Department of State Lands to approve the Coyote Island Terminal's Application (#49123) and allow the associated Morrow Pacific project to move forward.

The Morrow Pacific project has signed a letter of understanding with the Pendleton Building & Construction Trades Council that ensures the Port of Morrow facility will be built with 100% local union labor. Construction of the Port of Morrow facility will employ over 90 people in phase one, and at least an additional 65 in phase two. This project will also generate property taxes, port fees and make a voluntary contridution to support local schools.

Our members care about the environment. We hunt, fish, camp, boat and enjoy all that Oregon's great outdoors has to offer. We want a clean environment. But we also want an opportunity to go to work on projects that meet Oregon's high standards. The Morrow Pacific project does exactly that. The projects has undergone exhaustive review at both the state and federal level to ensure that it meets or exceeds Oregon's high environmental and land use standards.

We support the Morrow Pacific project not only for the jobs it will create for our union members, but for the economic development that can help pull our state out of the recession. Oregon's construction industry has been hard hit in recent years. Our union members have struggled with unemployment rate between 35 and 60%. We wnat a chance to go back to work, support our families, and build our local communities.

I wholeheartedly support the Morrow Pacific project and urge the Department of State Lands to move the project forward.

Chuck Little
Secretary-Treasurer
Pendleton Building & Construction Trades Council
NAME: Darin McCarthy
CITY: Portland
STATE: OR
AGENCY: Boilermakers Local 500
COMMENTS:
-- #49123 permit required.
-- Adverse effects not expected to be unreasonable.

On Behalf of Boilermakers Local 500 I urge the Oregon Department of State Lands to approve the Coyote Island Terminal's Application (#49123) and allow the associated Morrow Project to move forward. The design of the buildings for the coal trains to enter meet the highest of standards when it come to capturing the coal dust from the trains while being unloaded.The six filter houses, three on each side will capture any coal dust stirred up in the building while the trains are being unloaded.Also the fully enclosed conveyor system for loading the barges will prevent coal and coal dust from excaping while loading is taking place.Our members care about the environment just like other Oregonians.But we also need the jobs in this state my members have suffered 50% unemployment over the past 4 years.So i support the Morrow Pacific project and urge the Department of State Lands to move the project forward.
Thank You
Darin McCarthy
Bus. Mgr
Boilermakers L-500
NAME: Matt Brown
CITY: Portland
STATE: OR
AGENCY: Oregon Department of State Lands
COMMENTS:
-- No adverse effects expected.

Subject: Coyote Island Terminal’s Application (#49123)

On behalf of Foss Maritime, I encourage the Oregon Department of State Lands move to approve Coyote Island Terminal’s Application (#49123) and support the associated Morrow Pacific Project.

Foss has been serving the marine transportation needs of the Northwest – including the Columbia and Snake River system, for well over a century with a company-wide commitment to safety and the environment. In reviewing the Morrow Pacific project, it is clear that the project's developer Ambre Energy shares our commitment.

The Morrow Pacific project is designed to mitigate environmental impact along the Columbia River Gorge. By using inland barge to transport coal from the Port of Morrow to St. Helens, the project will be utilizing the safest, most fuel efficient means of transport available. One 15-barge tow carries the equivalent of 2.25 unit coal trains, or 900 trucks of coal. A barge can also transport one ton of material more than 500 miles per gallon of fuel, compared to 202 miles per gallon by rail and 59 miles per gallon by truck. Once implemented, the Morrow Pacific project will not increase congestion on Columbia River Gorge highways or rail lines.

Columbia River barge pilots are experienced, well trained and have an exemplary record of safety. And the Columbia River Pilots are on record in stating that the forecasted vessel traffic that would be created by the Morrow Pacific project poses no additional risk to navigation safety.

The Columbia Snake River System is a vital transportation link for the Northwest and for our nation. Oregon and its rural communities along the Columbia stand to benefit greatly from the economic benefit presented by this project. It is clear that these benefits can be enjoyed without compromising safety or the environmental quality cherished by all Oregonians.

I urge the Oregon Department of State Lands to approve the Morrow Pacific project.

Sincerely,
Foss Maritime Company

Matt Brown

NAME: William Smith
CITY: Kennewick
STATE: WA
AGENCY: OP&CMIA #478
COMMENTS:
-- 49123. permit required.
-- No adverse effects expected.

I would like to comment in support of this permit to move forward on this project. Our Local union represents members in Morrow & Umatilla counties of Oregon. This project would not only bring valuable construction jobs that would help our members and their families but it would add long term jobs that positively impact an area that has seen hard times. The construction and operations have taken into account environmental sensitivities of the river and the product that is going to be handled. The need for economic development significantly overshadows any adverse environmental impacts that would occur by allowing this project to move forward.
NAME: Heather Stebbings
CITY: Portland
STATE: OR
AGENCY: PNWA
COMMENTS:
-- #49123 permit required.
-- No adverse effects expected.

October 26, 2012

Mr. Charles Redon
WWC Comments
Oregon Department of State Lands
775 Summer St. N.E., Suite 100
Salem, Oregon 97301-1279

Dear Mr. Redon:

On behalf of the Pacific Northwest Waterways Association (PNWA), please accept these comments in response to the 49123-RF permit application for the Coyote Island Terminal/Morrow Pacific project.

PNWA is a regional trade association that advocates for federal policy and funding for navigation infrastructure projects in the Northwest. PNWA represents multiple industries in the public and private sectors in Oregon, Washington, Idaho, and California. Members include public ports, navigation, transportation, international trade, tourism, agriculture, forest products, energy and local government interests. Since its founding in 1934, PNWA led the way for development of economic infrastructure for navigation, electric power and irrigated agriculture on the Columbia and Snake River System. In 1971, PNWA expanded, adding Puget Sound and coastal port members to provide a comprehensive regional perspective. Today, PNWA works with the U.S. Congress, federal agencies and regional decision leaders on transportation, trade, tourism, energy and environmental policy to enhance economic vitality in the Pacific Northwest. Our full membership list is attached.

We would like to clarify some of the statements submitted in a recent comment period on the project. Our concerns fall into two categories: characterization of the Columbia Snake River System, and the request for an expanded scope and review process.

1. Columbia Snake River System

The Columbia Snake River System is a 470 mile vital transportation link for the states of Idaho, Montana, Oregon and Washington. These four states rely heavily upon the trade and commerce that flows up and down this system.

The river system has great local, regional and national benefits. It is the number one U.S. export gateway for wheat, and number one West Coast exporter of wood products and mineral bulks. It is the third largest grain export gateway in the world. In 2010, 42 million tons of cargo moved on the Lower Columbia River, supporting at least 40,000 local jobs.

The river system also provides the most fuel-efficient mode of transportation – barging carries more cargo and utilizes less energy than trucking and rail combined. Each year, barging keeps 700,000 trucks off the highways that run through the Columbia River Gorge.

An earlier comment letter described the Columbia River as a "confined system". Even with current trade levels, there is capacity in the river system. In CY2000, Bonneville Lock saw 3,436 lockages. In CY2011, however, Bonneville only had 2,505 lockages. These statistics were mirrored at other locks along the system, with The Dalles dam having 1,935 lockages in CY2011 and John Day having 1,654. Thanks to regular lock maintenance and repairs, there is significant capacity for vessel traffic to increase.

As the letter states, there are “multiple ports” along the river system. These ports move commerce in and out of the Pacific Northwest and play a vital role in local communities through job creation, port fees and property taxes. Most of the region’s ports have the capacity to expand and are actively cultivating new business. Indeed, the State of Oregon has already invested in the river system with the goal of enabling additional cargo to flow through our region.

In 2010, stakeholders celebrated the completion of the Columbia River Channel Improvement Project. The federal government, ports on the Lower Columbia River, and the states of Oregon and Washington invested over $183 million to deepen the Columbia River navigation channel to 43 feet. The purpose of this project was to make the river system more marketable and to bring new business to our region. Channel deepening, as well as significant recent lock repairs in 2010-2011, solidify the Columbia Snake River System’s position as one of the nation’s leading international trade gateways.

An earlier comment letter also questions the safety of the current navigation system. Regional stakeholders have worked hard to develop a comprehensive system to ensure safe and efficient navigation. The state-appointed Oregon Board of Maritime Pilots regulates and oversees our highly respected pilot associations on the river system - the Columbia River Pilots and Columbia River Bar Pilots.

The Columbia River Pilots, in conjunction with ports, vessels and shippers, currently tracks vessel movements with an advanced computer communication system called the Automatic Identification System (AIS). In a letter submitted to the Corps on April 4, 2012, The Columbia River Pilots responded to forecasted deep-draft vessel traffic that would be created by the proposed Morrow Pacific project. The letter stated:

Increased Vessel Traffic: The Morrow Pacific project anticipates that, depending on cargo volume, 58-133 vessels per year would be calling at the proposed terminal. COLRIP is of the opinion that this increased traffic level poses no additional safety concerns for vessels transiting the river system.

Navigation of Vessels: The vessels expected to call at the terminal are Panamax bulk carriers. Vessels of this type routinely call in the river system and pose no additional risk to navigation safety.

An earlier comment letter makes reference to our "breaking bar". Every year, the Columbia River Bar Pilots guide approximately 3,200 vessel crossings of the bar. Shippers, ports and Bar Pilots can attest to the safety and efficiency of our bar. The unique geography of the Columbia River bar is met by the skill and professionalism of the pilots. The Bar Pilots have indicated there is capacity to increase the number of vessel crossings above current and historical levels.

All of these groups work closely with the U.S. Coast Guard, U.S. Army Corps of Engineers, NOAA, ports and the shipping industry to ensure safe passage. The current navigation system is both safe and efficient, and primed to accept an increase in vessel traffic and tonnage.

2. Scope and Review Process

Some of the comment letters called for an expanded scope of review or in some cases, a programmatic Environmental Impact Statement (EIS). Regardless of the commodity moved, we support the current project level review. This process includes a reasonable scope and a thorough review by state and federal agencies. These processes provide opportunities for comment by elected officials and the public.

Increasing the scope of the review process would be inappropriate for this project and may set a precedent of similar requirements for other export projects. The permit requested by the Morrow Pacific project is for a dock permit, similar to what could be requested for other commodities including grain, aggregate, ethanol and more.

In evaluating permits, state and federal agencies play the critical role of gatekeeper. Requests for expanding the scope of the review process amount to a significant public policy shift. In addition, a programmatic EIS could include review of projects that have not even submitted a permit application. It would be irresponsible of these agencies to spend federal and state dollars to review projects that are no further than the infancy stage.

The requests for an expanded scope, which would certainly delay or kill projects, are also at odds with the national and regional goals to increase exports. In March 2010 as part of the Administration’s National Export Initiative, President Obama announced an ambitious goal of doubling exports within five years. At a recent port meeting Governor Kitzhaber highlighted the importance of the export market to the Oregon economy and pledged to continue “scouring the state” for new export business.

For 78 years, PNWA has effectively advocated for the region’s navigation projects and broader regional economic development. Our members often are their community’s most effective – or only – voice for jobs. We have advocated for the river system since 1934 because of the jobs and economic opportunity it provides for Northwest communities. We respect and support the agency’s thorough review process and encourage you to maintain the current scope and process.

Thank you for considering these comments.

Sincerely,

Kristin Meira
Executive Director
Pacific Northwest Waterways Association

PNWA Membership Roster
AECOM
Advanced American Construction
Allan Rumbaugh
Alaska Assoc. of Port Managers &
Harbormasters
Ball Janik LLP
Bell Buoy Crab Co.
Benton County PUD #1
BergerABAM Engineers, Inc.
Bergerson Construction
Bernert Barge Lines
BST Associates
Business Oregon-Infrastructure
Finance Authority
Central Oregon Basalt Products, Inc.
Central Washington Grain Growers
Clark Public Utilities
Clearwater Paper
Columbia Basin Development League
Columbia Grain
Columbia River Bar Pilots
Columbia River Pilots
Columbia River Steamship Operators
Association
Cooperative Agricultural Producers
David Evans & Associates
Dunlap Towing Company
The Dutra Group
East Columbia Basin Irrigation District
EGT, LLC
Evergreen Engineering
Foss Maritime Company
Franklin PUD
Gordon Thomas Honeywell Government Affairs
Great Lakes Dredge & Dock
Hart Crowser
Wally Hickerson
ICF International
ID Wheat Commission
International Longshore and Warehouse Union (ILWU)
J.E. McAmis, Inc.
Kalama Export Company
KPFF Consulting Engineers, Inc.
Kiewit
Lampson International, LLC
Landau Associates, Inc.
LD Commodities
Lewis-Clark Terminal Association
Longview Fibre Company
MacKay & Sposito, Inc.
Manson Construction
Marine Industrial Construction
Maul Foster & Alongi, Inc.
McGregor Company
McMillan
Millennium Bulk Terminals
Moffatt & Nichol
Morrow Pacific
Normandeau and Associates
Northwest Grain Growers, Inc.
Northwest Public Power Association
Oregon Int’l Port of Coos Bay
OR Public Ports Association
OR Wheat Growers League
Pacific Northwest Farmers Cooperative
Parametrix
Parsons Brinckerhoff
PBS Engineering & Environmental
PND Engineers, Inc.
PNGC Power
Pomeroy Grain Growers
Port of Astoria
Port of Bandon
Port of Benton
Port of Camas-Washougal
Port of Cascade Locks
Port of Chelan County
Port of Chinook
Port of Clarkston
Port of Columbia County
Port of Garibaldi
Port of Hood River
Port of Humboldt Bay
Port of Ilwaco
Port of Kalama
Port of Klickitat
Port of Lewiston
Port of Longview
Port of Mattawa
Port of Morrow
Port of Newport
Port of Pasco
Port of Port Angeles
Port of Portland
Port of Ridgefield
Port of Royal Slope
Port of Seattle
Port of Siuslaw
Port of Skagit
Port of St. Helens
Port of Sunnyside
Port of Tacoma
Port of Toledo
Port of Umatilla
Port of Umpqua
Port of Vancouver
Port of Walla Walla
Port of Whitman County
Port of Woodland
Puget Sound Pilots
Schnitzer Steel
Schwabe, Williamson & Wyatt
SDS Tug & Barge
Seattle Public Utilities
Shaver Transportation Company
Stoel Rives LLP
Strategies 360
Teevin Brothers
TEMCO, LLC
Tidewater Barge Lines
Ukiah Engineering, Inc.
United Grain
USA Dry Pea & Lentil Council
WA Association of Wheat Growers
WA Council on International Trade
WA Public Ports Association
WA State Potato Commission
WA Grain Commission
Westwood Shipping
Weyerhaeuser Company
Whole Brain Creative, Inc.
Wildlands, Inc.
NAME: Patricia J Weber
CITY: Corvallis
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

I support the Columbia River Intertribal Fisheries Commission's call for a full EIS on all proposed coal export terminals in the northwest, to be evaluated in conjunction with the environmental impacts of using the railroad infrastructure to transport coal. The risks to the tribes' economical well-being is too great to justify the minimal review that is being accorded by this application process. Please deny this permit.
NAME: LeeAnne Beres
CITY: Seattle
STATE: WA
AGENCY: Earth Ministry/Washington Interfaith Power & Light
COMMENTS:
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.

Re: Application of Coyote Island Terminals, LLC, Mr. John Thomas, Ambre Energy North America,
170 S. Main Street Suite 700, Salt Lake City, Utah 84101
US Army Corps of Engineers No: NWP-2012-56; Application Number: APP0049123

October 29, 2012

Dear Mr. Charles Redon:

We write to you as Oregon and Washington religious leaders in reference to the Army Corps of Engineers declining to require an Environmental Impact Statement for the Morrow Pacific Project, and the lack of sufficient opportunity for the public to comment on this controversial project.

As you prepare to make a far-reaching decision about the health and future of the Pacific Northwest, and indeed the whole of Earth’s atmosphere, we ask you to please consider God’s call to protect human health and to steward creation.

We have concerns about whether Ambre Energy is acting in the public interest by proposing to ship at least 8.8 million tons of coal annually by train through communities from Billings, MT to the Port of Morrow, OR; by barge on the Columbia River from the Port of Morrow to the Port of St. Helens, OR; and by ship from the Port of St. Helens to Asian countries.

The effects of transporting this coal are huge, creating safety and health concerns all along the rail lines and throughout the waterways of both Oregon and Washington. There are many moral and ethical questions involved in this proposal, questions that can only be answered by a comprehensive environmental and public review.

Those who are worried about our communities come from a broad cross-section of federal agencies, state governments, local municipalities, health professionals, recreationists, religious leaders, and Native Tribes – all concerned over the nature and extent of the environmental and health impacts of the proposed coal export terminal at Morrow.

More than 25,000 citizens have submitted comments to the Corps requesting a careful analysis of the impacts of this particular proposal. At this point in time, however, the Corps is not requiring an Environmental Impact Statement for the proposed Morrow coal export terminal.

We ask that you require a full EIS for the Morrow Pacific Project.

Furthermore, it has also come to our attention that the Corps may decide to issue permits for the Morrow Pacific Project without any additional opportunity for public comment. Our communities must weigh in: we all have a stake in the health of our fishing and farming communities and the future of our children in a changing climate. Please consider our input.

Despite an outpouring of concern from the region calling for a look at the impacts of coal from mine to power plant, it appears that the Corps may decide to do just the opposite—to conduct a very narrow analysis without considering these fundamental issues and without allowing for any reasonable public input on environmental and health impacts. We know that the Army Corps can do better than this in serving the public interest.

As religious leaders in the region, we call upon the Army Corps of Engineers to require an Environmental Impact Statement for the Morrow Pacific Project and to open an official public comment period on current documents. The health of God’s creation and the future of our children depend on it.
Thank you for your consideration.

Sincerely,

The Rt. Rev. James E. Waggoner, Jr.
Bishop, Episcopal Diocese of Spokane (Eastern Washington)

The Rt. Rev. Greg Rickel
Bishop, Episcopal Diocese of Olympia (Western Washington)

Rev. Martin Wells
Bishop, Eastern Washington-Idaho Synod, Evangelical Lutheran Church in America

Rev. Wm. Chris Boerger
Bishop, Northwest Washington Synod, Evangelical Lutheran Church in America

Rev. Dave Brauer-Rieke
Bishop, Oregon Synod, Evangelical Lutheran Church in America

Rev. Marcia J. Patton
Executive Minister, Evergreen Association of American Baptist Churches

Rev. Michael Denton
Conference Minister, Pacific Northwest Conference, United Church of Christ

LeeAnne Beres
Executive Director, Earth Ministry/Washington Interfaith Power & Light

Jackie O’Ryan and Paul Benz
Co-directors, Faith Action Network

Rev. Carol McKinley
Coordinator, Washington State Unitarian Universalist Voices for Justice

Sam Merrill
Chair, Friends Committee on Washington Public Policy (Quakers)

Jenny Holmes
Director, Oregon Interfaith Power & Light

Rev. Tim Phillips
Lead Pastor, Seattle First Baptist Church

NAME: delia sanchez
CITY: grand ronde
STATE: OR
AGENCY: confederated tribes of Grand Ronde
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Recommend permit denial.

I am a member of the confederated tribes of Grand Ronde, I am chinook from the portland vancouver area. exporting coal will poison the air and water to say the least. exporting coal out of the northwest will hurt the next 7 generations to come.. please stand up for the children
NAME: Joanne Skirving
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

To protect public health, I urge you to deny the pending removal-fill permit for Ambre Energy's Morrow Pacific coal export project. This project would pollute Oregon's air and water and expedite global climate change. Please defend Oregonians' land, health, and water by rejecting this project.

NAME: Gary Neal
CITY: Boardman
STATE: OR
AGENCY: Port of Morrow
COMMENTS:
-- 49123 permit required.
-- No adverse effects expected.

As the Manager of the Port of Morrow, I am writing to ask the Department of State Lands to approve permit application #49123 for the Coyote Island Terminal dock. The dock is part of a larger bulk materials transfer project at the Port of Morrow. The project is environmentally sound and will create critical jobs in Morrow County and the State of Oregon.

The Port of Morrow focuses on bringing jobs to rural Oregon. After Coyote Island Terminal's evaluation of available sites, the Port leased approximately 40 acres to Coyote Island Terminal with the understanding that the company would operate at the highest environmental standard while bringing up to 451 construction jobs and 28 full-time jobs to Morrow County.

The project comes at a time when losses from the recession and the forthcoming PGE power plant shutdown are gravely hurting our local communities. The project helps restore economic value by adding family wage jobs and contributing nearly $3 million in taxes to Morrow County. In addition, Coyote Island Terminal will voluntarily contribute $800,000 annually to the local school system. If the project is not allowed to move forward, the economic cost to Morrow County, and the state, is simply irresponsible.

The dock is similar to any other bulk handling operation on the river, all of which have been evaluated and found acceptable under this exact process. If any difference exists, it is that Coyote Island Terminal has gone above industry and area standards to design a state-of-the-art, environmentally advanced facility and dock. The facility, consisting of a rail unloading shed, enclosed storage buildings, enclosed conveyor, and barge loading dock, have been designed to completely enclose the product. From the time the trains are unloaded until the time coal is delivered to customers, coal will never be exposed.

Dock construction includes Best Management Practices to minimize harm to fish and aquatic habitat. Coyote Island Terminal will use isolation curtains, vibratory hammer installation, and bubble curtains, when necessary. In addition, Coyote Island Terminal will avoid impacts to the bank. Mitigation includes bank planting, which is needed in the reach, and removal of derelict piles. Dock construction activities are similar to others that have been installed recently and will not have long-term negative impacts on aquatic resources.

The facility and dock are located in our industrial area, between two existing docks, in an area of commercial use. Since the dock is in the middle of the Port Industrial Area, adverse impacts to fishing, recreation, and other commerce are not anticipated.

I encourage the DSL to approve this application, as they have other similar projects in the area. The dock design meets Oregon’s high environmental standards and the project brings much needed economic activity to Morrow County and the state.
NAME: Susan Isabel Boyd
CITY: Union
STATE: OR
AGENCY: Lucille H Carter Irrevocable Trust
COMMENTS:
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.

Do not approve this application before a full environmental impact statement that considers the effect the project would have on wheat transport along the same route. We already have a viable agricultural economy in Oregon.
NAME: Lawrence and Catherine Shadbolt
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Recommend permit denial.

We request that you deny the pending State of Oregon removal-fill permit for Ambre’s Energy’s Morrow Pacific coal export as inconsistent with the protection, conservation, and best use of the state’s water resources for all citizens of the state.

Ambre’s project will adversely impact the water quality of the Columbia River due to toxic coal and diesel fuel emissions from the transport and loading to and from the proposed site. The project will also interfere with navigation, public recreation, and access to tribal fishing sites and archeological sites on the River. Ambre’s proposed plan does not fully address these impacts, and the permit should be denied.


NAME: Page Atcheson
CITY: Helena
STATE: MT
AGENCY:
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to water resources.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

I believe the Coyote Island Terminal should be required to conduct a thorough Environmental Impact Statement. Because this terminal will export coal coming from the Powder River Basin in Montana and Wyoming, the impacts of building it extend far beyond the terminal itself. Please consider the impacts of coal development (to land, water, and rancher's livelihoods), increased coal train traffic (especially serious health concerns), AND climate change. Thank you.
NAME: Lynn Baker
CITY: Portland
STATE: OR
AGENCY:
COMMENTS:
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

Overriding this entire project is how it will contribute to global warming with its greenhouse gases. Morally indefensible. Closer to home, the jobs created are not going to make up for health risks to people living close to the rail lines, to pollution of the Columbia River and the historic Columbia Gorge, and resultant impact on fish and wildlife.
NAME: Jenny Holmes
CITY: Portland
STATE: OR
AGENCY: Ecumenical Ministries of Oregon, OIPL
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Recommend permit denial.


October 31, 2012

Oregon Department of State Lands
775 Summer Street, NW
Salem, OR 97301-1279

ATTN: Charles Redon, Resource Coordinator, Removal-Fill Permit

RE: Coyote Island Terminal, LLC Application APP0049123 Morrow County 23 Morrow County

Dear Governor Kitzhaber and Members of the State Land Board,

Since 2001,Oregon Interfaith Power and Light, a project of Ecumenical Ministries of Oregon, has advocated, educated and taken hands on action to enable the development of clean renewable energy and expansion of energy efficiency in Oregon and in our nation. It is disheartening see the Pacific Northwest’s shorelines proposed for facilities to export coal to Asia.

As people of faith informed by values of justice and stewardship of creation, we call on you to deny the pending State of Oregon removal-fill permit for Ambre’s Energy’s Morrow Pacific coal export project.

The health of the Columbia River, a lifeblood to the economy, the cultures and the well-being of people of the Pacific Northwest, should be foremost in mind in permitting decisions on its shorelines. Ambre’s project will adversely impact the water quality of the Columbia River due to the transport and loading of toxic coal to and from the proposed site, and increased diesel fuel emissions. The project will also interfere with navigation, public recreation, and access to tribal fishing sites and archeological sites. Ambre’s proposed plan does not address these impacts and is not consistent with the protection, conservation and best use of our state’s water resources.

Therefore, OIPL urges you to deny the removal-fill permit until a programmatic, area-wide Environmental Impact Statement can be completed on this project, and others being proposed In Oregon and Washington that would affect water quality and use of the Columbia River. We are called to be good stewards of the land and water for the benefit of all. The proposed project will undermine the common good.

Thank you for your consideration,
Jenny Holmes, EMO Environmental Ministries Director for the OIPL Steering Committee

NAME: Frank Foti
CITY: Portland
STATE: OR
AGENCY: Vigor Industrial
COMMENTS:
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.

Vigor Industrial Letter of Support for the Morrow Pacific Project
​Application #49123
 
I am writing to offer my strong support for the Coyote Island Terminal Application (#49123) . Ambre Energy's Coyote Island Terminal dock and the associated Morrow Pacific project demonstrate that a healthy environment and economic opportunity can go hand in hand. The dock proposed by Coyote Island Terminal at the Port of Morrow clearly conforms to the DSL approval criteria under the Removal-Fill Law.
 
Vigor Industrial has reviewed the project application, and believes that neither the Morrow Pacific Export project nor the proposed Coyote Island Terminal will adversely impact navigation, water quality, habitat, or public recreation.  The Morrow Pacific Export project uses the transportation infrastructure of the Columbia River that has been in place for over fifty years.  This infrastructure was intentionally developed to facilitate unimpeded navigation and movement of waterborne freight on the Columbia River.  The Morrow Pacific Export project proposes to use this infrastructure to transport freight from Coyote Island Terminal to Port Westward, Oregon, then on to overseas markets. This use is consistent and compatible with other existing uses of the transportation corridor on the Columbia River.
 
The Coyote Island Terminal dock is consistent in its design and function with other freight terminals existing near the project location and throughout the Columbia River system.  The approach to constructing the dock described in the application employs numerous measures to minimize the potential short-term impacts to fish and nearby shoreline habitat.  Once built, the design of the structure incorporates features to minimize impacts to the environment, such as minimizing shadow casting on the underlying waterway and eliminating the potential for the product to enter the water. Since the project is located at the Port of Morrow, which is an established port facility serving freight movement on the river, recreational river users will experience little if any new impacts from the project.  Finally, the project is located in the John Day Pool of the Columbia River, which is already highly altered from its natural state.  As such, the project will have limited, if any, adverse impacts on water resources or aquatic habitat.    
 
In closing, the Morrow Pacific project is an extremely well planned venture that capitalizes on the existing transportation infrastructure that has been planned and developed for decades.  The Coyote Island Terminal is an appropriate intermodal addition to this infrastructure that ties rail to marine, at an existing port facility that has seen heavy public investment in preparation for just this type of project.  In addition, the construction, manufacturing, and export jobs associated with the overall project are very important to the growth and diversification of our region’s economy.
 
I urge the Department of State Lands to expeditiously approve the application.
 
 

NAME: Pharmd635
CITY:
STATE: OR
AGENCY:
COMMENTS:

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CITY:
STATE: OR
AGENCY:
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NAME: John
CITY: UONbZwMSw
STATE: OR
AGENCY: rdRpCtltkR
COMMENTS:

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NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

-1'
NAME: 1
CITY: 1
STATE: -1'
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: David Perk
CITY: Seattle
STATE: WA
AGENCY:
COMMENTS:
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.

In November 2012 the Washington State Department of Ecology announced efforts aimed at measuring, studying and mitigating the effects of ocean acidification.

Please see this site for details:
http://www.ecy.wa.gov/water/marine/oceanacidification.html

The $3.3 million dollar per year initiative seeks to protect Washington State's shellfish industry, a source of 3,200 jobs and $270 million dollars of economic activity.

When burned, coal puts CO2 into the atmosphere that is, in part, absorbed by the oceans, raising their acidity. Heightened levels of ocean acidity prevent shellfish larvae from forming shells.

When burned, the coal exported from the Coyote Island Terminal would raise the baseline level of absorbed CO2 in the Pacific Ocean. This adverse impact is in direct conflict with the efforts of the Washington State Department of Ecology to mitigate the acidity of Washington's coastal waters.

The most efficient mitagation of this adverse impact is to not allow the coal to be consumed. For this reason the Coyote Terminal permit should be denied.
NAME: Tim Norgren
CITY: The Dalles
STATE: OR
AGENCY: independent citizen
COMMENTS:
-- Recommend permit denial.

My name’s Tim Norgren. I’m a union Laborer out of Local 320. I write you now to express whole-hearted opposition to the proposed export system on behalf of myself, my wife, and many friends in the gorge. I stand opposed to it because I have too much love for my family, friends, and this incredible place we call home NOT to.
It’s no small thing that this is home. I grew up in Michigan and then traveled extensively before putting down roots here, because it’s here that I’ve felt a greater connection and inspiration from the natural world than anywhere else. I love the hiking, fishing, water sports, and the clean forest air. But sadly, the more industry moves in, and the more I learn, the less I trust the waters and fish therein. I’m now apprehensive about buying salmon from the natives because pollution has increased so much. And that brings me sadness already.
So the idea of allowing an energy company with a reputation for dishonesty and reckless pollution to run tons of coal with its list of poisons over our towns and woodlands and waterways…past our playgrounds and backyard gardens…that strikes me as not only myopic, but insane. The fact is that the people behind this proposal live far away from the gorge. They don’t care about the people here, WORKERS INCLUDED, any more than they care about the Asians working in asthmatic sweatshops at tasks which once provided safe, living wage jobs here at home!
And when those unregulated factories burn this coal in Asia, science has proven time and time again that the prevailing winds blow smog across the entire Pacific, with much of it ending up here on our west coat and effecting climate globally. Meanwhile, company executives laugh at having cheated American regulations. They thumb their nose, believing our representatives too well lobbied, and our federal agencies too small, specialized, and short-sighted to oppose them.
But you CAN prove them wrong. The Oregon Department of State Lands and other agencies do have the power in the case, and I implore you to use it to protect us!
Thank you.

NAME: John Wood
CITY: Hood River
STATE: OR
AGENCY:
COMMENTS:
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Recommend permit denial.

Coal trains lose dust and particles into the air, soil, and water which erodes the quality of life of humans and the possibility of it for endangered species. After China burns our coal, the smoke pollutes the jet stream with greenhouse gases and heavy metal fallout. This acidifies Oregon soils and does the United States of America no long term good, and the short term benefits accrue only to a very few. Deny, please. Thank you.
NAME: Pharmf50
CITY:
STATE: OR
AGENCY:
COMMENTS:

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NAME: Pharmb542
CITY:
STATE: OR
AGENCY:
COMMENTS:

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NAME: Pharmg902
CITY:
STATE: OR
AGENCY:
COMMENTS:

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NAME: ByncadareeBer
CITY: Kralupy Nad Vltavou
STATE: OR
AGENCY: #file_links[C:\Xrumer\PROEKT\L.txt,1,S]
COMMENTS:
-- No comment.

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NAME: Madeleine Brown
CITY: Richland
STATE: WA
AGENCY:
COMMENTS:
-- Expect adverse impact to State- or federally-listed species.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.

Coal comments.
1. Make permit materials easier to find online. The link to permit application materials on the public notice had 82 characters. Those who received the notice in hard copy needed to perfectly record the 82 characters, which is truly difficult for many. I made a tinyurl for this site using http://tinyurl.com. DSL should have done this too. In future, don't give public long links.
2. The project has been designed to minimize train traffic through urban areas,” the application cites in the “purpose” section. Yet nothing in application supports this hopeful claim, and its falsity raises questions about the larger process.
3. “Need” section claims our Asian trade allies need America’s coal, but closer to these nations are many other sources of coal, such as Australia, Indonesia, and China. In fact, Australia and Indonesia are the world’s top exporters of coal. See: http://www.sightline.org/wp-content/uploads/downloads/2012/10/marketanalysis_2012.pdf for analysis that shows a dubious market for American coal to cross the planet’s largest ocean.
4. The project will adversely impact state and/or federally listed species. Application has misstatements. There are no suitable nesting trees in the project area. (permit application, page 13) fails to consider that many migratory species do not nest in trees. Further, photographs 1 and 2 of application clearly shows a tree that could have migratory bird nests.
5. The compensatory mitigation is insufficient to compensate for the reasonably expected adverse impacts of the project. Permit must make clear and direct “must” statements for revegetation. On page 14, application states: The woody species should be watered for three years, or until established. The vegetated areas will be monitored yearly to ensure species establishment. Areas not established after a full growing season should be mitigated by reevaluating the seed mix, including site preparation, and reseeding. This language does not say who should do the work, nor does it state the work will indeed be done. Permit language must me much more specific and direct. Example: “The permittee must water the revegetated area [state interval or another specific qualifier] for three years during [state months or seasons].

NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

-1'
NAME: 1
CITY: 1
STATE: -1'
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: -1'
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: -1'
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- -1' permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: 1
CITY: 1
STATE: al
AGENCY: 1
COMMENTS:
-- 1 permit required.
-- No adverse effects expected.
-- Adverse effects not expected to be unreasonable.
-- Advise change to design or methodology.
-- An alternate site or design should be investigated.
-- Expect adverse impact to State- or federally-listed species.
-- Expect adverse impact to archeological or historical site.
-- Expect adverse impact to water resources.
-- Project will unreasonably interfere with navigation, fishing and/or public recreation.
-- Compensatory mitigation insufficient to compensate for adverse impacts.
-- Recommend permit denial.
-- No comment.

1
NAME: Pam Whiteman
CITY: Hood River
STATE: OR
AGENCY:
COMMENTS:
-- Expect adverse impact to water resources.

I am deeply concerned about the impacts of train traffic on delaying emergency responders, damaging aquatic ecosystems and fishing grounds at the terminal site, and the potential for serious shipping accidents that could have severe environmental and health consequences. Based on BNSF own estimates, thousands of pounds of fugitive coal dust would be deposited in the Gorge every day, damaging human health and the environment. Please deny these permits and stop this project. The future health of our land, animals and our children are at stake!!!
 
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