Comment EI-19949
Received or sent (printed as 1/11/2013)
This proposed activity is extracting coal from the ground, transporting the coal, and burning the coal. One byproduct of this activity is greenhouse gases, both from burning the coal directly and the extraction and transportation process. The agency should consider the greenhouse gas emissions in its environmental impact. It should also consider the impacts of increased atmospheric greenhouse gas concentrations on the earth system. Scientists from numerous natural science disciplines are studying how the earth system is affected by increased atmospheric greenhouse gas concentrations. These studies should be taken into account in the environmental impact of the activity. One may conclude, however, that atmospheric greenhouse gas concentrations are rising due to emissions from all over the world, and so the marginal increase in concentration due to this coal extraction, transportation, and combustion, does not significantly contribute to the greenhouse gas concentration increase. This reasoning – while logical – is faulty. Under this reasoning the greenhouse gas emissions from the activity are not considered because they are just one small part of a massive problem. The problem, however, is really just the cumulative effect of millions of small parts. While this coal is only a small part of a massive problem, it must be recognized for its role in exacerbating that problem. Indeed, scientists recognize that the greenhouse gas emission rate must decrease (and some scientists argue that the greenhouse gas concentration itself must decrease) to mitigate the harm to the earth system from the increased greenhouse gas concentration. Since this decrease is the requirement for mitigating harm, any activity that does not contribute to decreasing the emission rate should be considered as contributing to the problems caused by the increased greenhouse gas concentration. In other words, all fossil fuel extraction activities must be considered to be causing the harm from the increased greenhouse gas concentration, because each extraction is contributing to that harm by preventing a decrease in the emission rate. The alternative that must be explored is leaving the coal in the ground. A fair impact assessment will include this as an alternative. “No action” does not just mean “not this transportation route” but rather “not this coal extraction.” We have a right to know the environmental impact of extracting this coal, and the agency should take this impact into account in making its decision.
Submitted by: Lindsey Schromen-Wawrin · Spokane, Washington
The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.
Permanent address docketyard.org/d/FD-30186/comment/EI-19949 · back to the docket sheet