No LNG No Pipeline

Points for Writing Comments to the Army Corps on the
Port of Coos Bay Dredging Project

Drafted by the Oregon No LNG Exports Coalition   

Background: The U.S Army Corps of Engineers is preparing an Environmental Impact
Statement (EIS) to analyze the potential environmental effects of approving a major dredging project on the Bay. The project proposes to widen and deepen the Coos Bay Federal Navigation Project from the ocean to river mile (RM) 8.2 to so that large tankers can fit in the bay to transport the LNG overseas. The Army Corps of Engineers is looking for comments on what issues to cover in their Environmental impact Statement (EIS). We can raise issues on everything ranging from navigation concerns, socioeconomics, fish and wildlife, water quality, safety, shoreline erosion and accretion, recreation, and cultural and historic resources and more. Scoping comments will also be used to develop possible project alternatives.

Submitting Comments: All interested parties are invited to submit written comments on or before October 3, 2017 to the:
U.S. Army Corps of Engineers, Portland District (PM-E), P. O. Box 2946, Portland, OR 97208-2946,
or by email to: coosbaychannelmodEIS@usace.army.mil
All comments should include “Coos Bay Channel Modification Project EIS” in the subject line.

Suggested topics for the scope of the EIS (note: once the EIS is drafted there will be more oportunities to state our opposition, the scoping process is to determine what issues the EIS will cover).

1) Project purpose: The Public Notice for dredging does not state the reasoning for
channel modification (e.g. they don’t say it’s for Jordan Cove LNG even though it’s pretty clear the project would almost exclusively benefit that project)
● In the Draft Environmental Impact Statement (DEIS), the Corps must
demonstrate why it is necessary to widen and deepen the channel, and whether
that purpose can be met without modifying the Coos Bay Federal Navigation
Channel. This should also include evaluation of the types and numbers of
shipping projected for Coos Bay.
● The Corps has not stated a clear purpose for the widening and deepening of the
Coos Bay Federal Navigation Channel.
● The US Army Corps of Engineers must clarify purpose of the dredging request

2) This is a connected action to the Jordan Cove LNG Export Project
● There is a very similar proposal to dredge the channel, dispose the dredged
material offshore, and increase access for ship traffic for the Jordan Cove LNG
Export Project.
● The Corps should do a full review of the direct, indirect, and cumulative effects of
modifying the channel and disposing of the dredged material offshore in the
context of the proposed LNG terminal and Pacific Connector Pipeline as a
connected action.

3) Public Trust: This impacts our public trust right of fishing, access, and water use.
● Being able to use and access waters for fishing is one of our most basic public
trust rights in Oregon (According to the case: Oregon Shores Conservation
Coalition v. Oregon Fish and Wildlife Comm’n, 62 Or App 481, 493 (1983))
● Modifying the channel will have significant impacts to fishing and shellfishing
areas within Coos Bay. This would negatively impact the economic value of
fisheries in the area.
● Modifying the channel may interfere with the ability of the public to access these
areas for fishing and other general water uses. This would negatively impact the
outdoor recreation industry in the area.

4) Extent and Impact of Channel Deepening: EIS should consider the direct, indirect
and cumulative impacts to the estuary
● The proposed dredging and disposal associated with the channel modification
will likely cause direct, indirect, and cumulative impacts to the estuary, including
impacts to fish and wildlife, vegetation, water quality, geomorphology, and
tsunami risk.
● The EIS needs to consider the direct, indirect, and cumulative impacts of the
proposed dredging:
○ The EIS should consider how widening and deepening the channel could
change tidal dynamics, alter the bottom of the estuary which is important
habitat, and increase tsunami hazard.
○ The EIS should consider impacts to water quality from dredging and
disposal, including but not limited to dissolved oxygen, salinity,
temperature, fecal coliform, and sediment contaminants.
○ Since the dredging could destroy important habitat for fish, oysters, clams
the EIS should consider the biological impacts, including but not limited to
benthic organisms, fish, marine mammals, and invasive species.
● The Corps should determine whether this project has the potential to violate the
Oregon water quality standards for dissolved oxygen and sediment.

5) Coastal Zone Management Act: The State of Oregon must be allowed to determine
if the project complies with the Coastal Zone Management Act.
● The Department of Land Conservation and Development has the authority to
review federal permits that require federal consistency review.
● The Corps cannot issue any permit until the State of Oregon determines if this
proposed project is consistent with the Oregon Coastal Zone Management Act.
● The EIS and Department of State Land Conservation and Development have to
demonstrate that the proposed project is in compliance with Statewide Planning
Goals, city and county land use plans, and state policies for water quality,
removal-fill, fish and wildlife.
● The Corps should consider their compliance with the Oregon Coastal Zone
Management Act by evaluating:
○ Impacts to coastal shorelines, estuaries and dunes under Statewide
Planning Goals 16, 17, and 18,
○ Impacts related to natural hazards under Statewide Planning Goal 7,
○ Impacts to natural resources, air, and water under Statewide Planning
Goal 5 and 6,
○ And requirements of state statutes and regulations about removal-fill,
water quality, and fish and wildlife protections.

6) Socioeconomic factors
● What impacts will dredging have to fishing, crabbing and oyster industries in the
bay?
● How will the project impact travel related to fishing, recreation and tourism?

7) Who Pays?
● Will the Port of Coos Bay be using public, taxpayer funds to develop the project?
If so, how much of the total cost is projected to be paid for by private companies.
● What companies stand to benefit the most from the project? What companies
stand to be negatively impacted?

8) Climate Impacts
● The Corps should consider the how widening the channel may increase traffic
from large tankers and the climate impacts of increased traffic in the bay.

9) Alternatives
● The Corps should rigorously explore and objectively evaluate all reasonable
alternatives, and for alternatives which were eliminated from detailed study,
briefly discuss the reasons for their having been eliminated.
● Devote substantial treatment to each alternative considered in detail including the
proposed action so that reviewers may evaluate their comparative merits.
● Include reasonable alternatives not within the jurisdiction of the lead agency.
● Include the alternative of no action

For more information on the Jordan Cove Project and Pacific Connector Pipeline, check out:  www.nolngexports.org