Sunday, October 18, 2015

Did the DEIS's properly address your scoping comment??

by Arnie Martin,   Citizens for a Clean Harbor

The draft Environmental Impact Statements (EISs) for the Westway Expansion Project and the Imperium Terminal Services Expansion Project [crude oil terminals] in Grays Harbor, were published Aug 31, 2015,  starting  the  60-day public comment period. The comment period starts August 31, 2015 and ends October 29, 2015.

The scoping comments made 2 years ago were to be a guide for the Department of Ecology in writing the Environmental Impact Study (EIS).

Now is the time to go back and look at the scoping comment(s) you submitted back in 2013/2014.

1. Review your scoping comments (comments are in Volume 2, Appendix A). 
    a.       Search for your comments by expanding the “Appendix A” list by clicking on the “+” to its left, then clicking on “Index of Comment Submissions Sorted by Commenter Name”, then scroll down to your name.
    b.      Carefully review your comment(s).

2. Were your concerns addressed in the draft EIS?
    a.       Search (using your exact words in the scoping comment – or a subset of those words) to find what the DEIS says in response to your comment.
    b.      Using “Ctrl” – “Shift” – “F” is the best way to find something buried in the text of the Volume 1.

3. Were your concerns adequately resolved?
    a.      Has the DEIS put in requirements that would have the project proponents change their plans to reduce the effects of the problem addressed in your comment?           
    b.      Does the DEIS just add some words that say that occurrence is “very unlikely” or “highly unlikely”. 
    c.      Does the DEIS simply have a sentence that states: “Compliance with the applicable regulations and permits described above is expected to reduce impacts on land and shoreline use. There would be no unavoidable and significant adverse impacts.” ?
    d.      Does the DEIS fail totally to mention your concerns?
    e.      Be aware that the studies used to prepare the DEIS are included in volumes 2 and 3.

4. Responding to the DEIS
    a.       If you don’t believe that such comments adequately address the concerns you raised in the scoping comment, call their attention to the comment, using the comment submission number assigned to your comment. 
    b.      Point out the inadequacy of their DEIS, relative to your scoping comment. They will have to respond to your comment, and modify the DEIS text for incorporation into the Final EIS.
Both Draft EISs are available on the Ecology website, In addition to the draft documents, the website also has links to fact sheets in English and Spanish. These fact sheets summarize key issue areas, the environmental review process, and the Westway and the Imperium [ now REG] expansion projects. The website has information on submitting comments and a link to the online comment form.

Comments that do not identify a specific project will be considered for both projects. All comments are valued equally.  Comments can be submitted:

By mail at:
Westway and Imperium Terminal Services Expansion Projects EISs
c/o ICF International
710 Second Street, Suite 550
Seattle, WA 98104

Online at:

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