Individual comment detail

White, Earl
Date: Jun. 11, 2014
I don't understand whish EIS and SEPA process is not consistent with CEQ guidance on co-lead situations like Cherry Point. In the CEQ 40 FAQS it clearly states that all significant impacts must be identified regardless of whether you have the authority to mitigate them and this means that the Corps cannot shirk their responsibility to prepare a complete EIS. This even made more clear in the 2014 publication that the CEQ and California did together, "Integrating NEPA and CEPA." That publication makes it clear that as co-lead the Corp is responsible for a complete EIS that can contain NEPA qualified contributions from the co-lead. The 40 FAQS also says that this situation qualifies for a programmatic EIS since all of the proposed projects have the common significant impact of "fossil fuel transport through Washington."

E. I. White
Retired Environmental Consultant
253 347-1969