Urge the Army Corps of Engineers to conduct a full and thorough EIS.
Join us in urging the Army Corps of Engineers to take a hard look at all of the potential direct, indirect, and cumulative impacts of Houston-based NEXT’s’ proposal to build and operate a massive new renewable diesel refinery at Port Westward in the Columbia River estuary.
Dear U.S. Army Corps of Engineers:
I support the Corps’ decision to conduct a full Environmental Impact Statement on NEXT’s proposed diesel refinery, (Corps Number NWP–2020–383). I urge the Corps to conduct a broad, in-depth analysis of the potential impacts from NEXT’s refinery, rail yard, and the dock at Port Westward. After careful analysis, the Corps should deny the Clean Water Act permit for this proposal. Producing, shipping, and storing millions of barrels of diesel in the Lower Columbia River could have major impacts locally and throughout the entire region, including to fisheries, downstream communities, and uprail communities. In the EIS, the Corps should:
- Define the proper purpose and need for the project. NEXT’s proposal would have region-wide impacts. Because NEXT could supply diesel to the West Coast and other markets, there are a broad range of alternatives available.
- Provide a reasonable range of alternatives. The EIS should look at alternatives to the project and alternative designs for the project. For example, the analysis should involve a robust no action alternative, a region-wide look at alternatives to the project (including increased vehicle electrification), alternative locations for the production and shipment of renewable diesel, and alternative project designs that pose fewer impacts.
- Take a hard look at all of the direct, indirect and cumulative impacts of the entire project and connected actions. How would the project impact the community, its health, safety, and the natural resources it depends on? How will the project impact the climate? (The project will emit over 1 million tons per year of climate-changing pollution at the refinery site, making it one of Oregon’s largest potential emitters, but that is only part of the picture.) What are the proposal's traffic impacts? Noise impacts? Odor impacts? What are the risks associated with diesel, chemical, or feedstock spills into water, both at the site (amid sensitive wetlands and farms) and along the rail line, shipping routes, or highways that NEXT will rely on to transport materials, feedstocks, and finished products? What air pollution impacts will occur in the region?
- Consider spill risks and other impacts to the whole Lower Columbia River. The project area is linchpin habitat for salmon recovery and survival. How would the refinery, its pollution, and its spill risks fit into regional approaches to salmon recovery and restoration?
- Address the full lifecycle impacts of NEXT’s proposal and fracked gas use. What are the lifecycle climate impacts of NEXT’s renewable diesel production? The EIS must address how much carbon dioxide, methane, and other pollution will be emitted as a result of the proposed refinery, rail yard, and the energy and materials they demand. How much fracked gas will be used, and what are the consequences of so much fracked gas use for the climate, regional pipeline capacity, and other regional gas users?
Thank you for considering these comments. I urge the Corps to conduct a broad, in-depth EIS that fully considers all direct, indirect, and cumulative impacts related to the proposed refinery and rail yard.