On Nov. 21st, I went to the County scoping meeting about the County's proposal to open Blue Lake Quarry, located off Ash Road, just outside Stevenson. I was the only citizen in attendance. There were handouts—the scoping meeting topics; a bundle of comments from state agencies, the Yakama Tribe, the city of Stevenson, and Wauna Lake gated community; WAC 197-11-444, Elements of the Environment; and, the Determination of Significance and Request for Comments on the Scope of the EIS (this version had the SEPA checklist attached). The County was looking for any additions to the scoping list, so I put in my two cents and said that geology and coring should be put with slope stability (the county engineer said that they have been using the quarry for so long that they know the slopes are stable!). The engineer from the contract firm said they would “lay” down the slopes as they quarry out the stone, to prevent slope instability. I said that coring could tell them if there is unstable ground beneath the excavations, and potential slide slopes, fault lines, etc. There are steep roads in this area and heavy trucks will be traveling on them—they estimate that there could be over ONE MILLION cubic yards of road rock taken out of the crushed material and that the quarry could operate for 100 years or more!). Also, I asked if they were going to do a Scenic Resources inventory list and they looked at me funny! I wanted to know what the scenic resources are and I believe the County should address this issue.
Trucks—they are estimating 10 round-trip truck trips, when they do use the quarry, using 10-cubic yard trucks.
The county engineer said that the slope stability or instability would be taken care of in the operations phase—that is, when they are already excavating. I disagreed. They should do a geological survey and have a geotechnical report done BEFORE they start, not after.
I also asked that Cumulative Impacts be added to the scoping discussion. The county engineer asked me to explain what I meant by CIs and so I did. I will be sending them the info on the CEQ’s Cumulative Impacts handbook. If the county is going to have the final say on this—and that is what Karen Witherspoon said they would have, since this isn’t going before the Gorge Commission (unless it is appealed, and then it would go before our Hearings Examiner first, then the GC, then to court, if necessary)—they should at least know how to do cumulative impacts analyses!! I told them the USFS NSA Manager’s office could probably help in this area.
Valerie and Craig will be working on the EIS. I asked about a timeline and Valerie said she doesn’t anticipate an EIS before Spring 2012.
The county has owned the quarry since 1925. They have a DNR permit to quarry, since 1971. In 1998, 5.1 acres were found to be of “non-conforming” use.Attendees at the meeting: Mark M., Karen W., Jessica Davenport, Valerie Oskoski (contract engineer), Craig Rendell (county Public Works), Tim H. (county engineer).
I thought of one other thing that should be in the scoping analyses—a cost/benefit analysis. It was stated at the meeting that operating this quarry will save the county money. Well, I don’t really know that it will or it won’t because we don’t have a cost/benefit analysis. At a minimum, it should cover how much it would cost the county to actually run the quarry, truck costs, excavation costs, etc. vs. what it costs to buy the rock from some other quarry (which has its own equipment, personnel, etc.). There are probably a lot of other things that go into a cost/benefit analysis and someone who is an expert should be consulted.
Cumulative Effects: The cumulative effects handbook—its full name is Considering Cumulative Effects: Under the National Environmental Policy Act, comes from the Council on Environmental Quality, Executive Office of the President. The following is the definition of cumulative impacts and how to start assessing them:
Council on Environmental Quality (CEQ)
Cumulative Effects Analysis
From CEQ Regulations §1508.7 Cumulative Impact
“Cumulative impact” is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.
Example: If the park proposes to expand a campground in grizzly bear habitat, other activities that have a combined impact on the grizzly bears must be included in the analysis. This would include other NPS road projects that would occur in grizzly bear habitat, as well as plans for future garbage disposal in the park's gateway communities and last year's Forest Service timber harvest. It doesn't matter who takes the actions, or whether they took place in the past, are taking place in the present, or will take place in the foreseeable future.
From DO-12, Conservation Planning and Environmental Impact Analysis
§4-5, G.6: “Cumulative impact information may be less exact than information on direct and indirect impacts of the alternatives, but a good faith effort to accurately and completely assess major sources of impact and their contribution to resources affected by the proposed action or alternatives should be part of any EIS or EA. For plans or other larger-scope federal actions, the analysis of cumulative effect may be a major focus of the NEPA document.”
Cumulative Impacts = Additive and Interactive
These impacts accumulate in the same way as a “straw on a camel's back.” Straws keep adding weight until, finally, the camel's back is broken. One impact, causing occurrence, such as a single gas well, may be of little significance. A hundred wells in the same area, however, may profoundly impact a given valued resource.
These impacts accrue as a result of assorted similar or dissimilar actions being taken that tend to have similar impacts, relevant to the valued resource in question. Vegetation quality, diversity, density, and general health, for instance, could be affected by several actions. These actions could include unmitigated over-grazing by wildlife/ wild horses/ burros, cattle, plus motorcycle/off-road vehicle use, industrial development, and roads.
How do I start?
- Consider what the geographic area should be for your affected resource. This area will differ from resource to resource. You might use regional watersheds, for example.
- Assemble a list of past, present, and reasonably foreseeable future actions called the “cumulative scenario.” Be sure to include actions that might be taken by other agencies or individuals that could also affect park resources.
- Work through the cumulative scenario and determine which actions are relevant to your impact topic. Focus on impacts that are clear contributors.
- Develop the cumulative impact analysis. You may want to think of cumulative impacts as x + y = z (with x being the impacts you have described as a result of actions being proposed under each alternative; y being past, present, and reasonably foreseeable future actions; and z being the cumulative impacts).
- Determine the context and intensity or magnitude of the actions. Intensity refers to the severity of the effect. Use the same terms that you used for your impact analysis - negligible, minor, moderate, and major.
- Describe the total impact for your topic. You should also highlight the relevant contributions of the NPS action proposed for the project or plan (compare x to z).
- Where possible, use quantifiable data. Realize that your analysis may be mainly qualitative.