Lummi Indian Business Council - EISs for the Proposed Gateway ...

Lummi Nation in particular associated with fishing interference, spills of hazardous materials,ocean acidification, acid rain, visibility impairment (due to sulfur dioxide and nitrogen oxideemissions), sea level rise and all of the other potential impacts associated with the proposedprojects.Like all of the potential project impacts, the analysis of economic impacts should specificallyconsider environmental justice and cumulative effects.10.3 Significant Unavoidable Adverse ImpactsElements of the proposed projects will preclude the ability and/or interfere with the ability ofthe Lummi People to exercise their treaty rights to fish throughout their U&A. – these impactswill result in significant, unavoidable, and unacceptable interference with our treaty rights andirreversible and irretrievable damage to our spiritual values if the proposed projects areapproved.11 Potential Impact: Ballast Water (Water Quality and Invasive Species)11.1 Issue Definition/Rationale:Because as described the proposed project will be primarily an export facility, ships calling onthe facility will need to discharge ballast water. This ballast water can originate from all overthe world and carry plants, animals, bacteria, and pathogens ranging in size from microscopic tolarge plants and free‐swimming fish. Non‐native organisms and pathogens introduced throughthe discharge of ballast water from vessels calling on the proposed facility and/or existingfacilities can significantly alter an ecosystem by competing with, preying upon, and/ordisplacing native or commercial species or invade and destroy the habitat that is critical tonative species. The displacement of native species, the degradation of native habitats, and thespreading of disease can disrupt social and economic activities that the Lummi Nation and itsmembers rely upon to preserve, promote, and protect our Schelangen (“way of life”).11.2 Extent/Geographic Scale of EvaluationImmediate AreaLocal AreaRegional AreaGlobal AreaThe EIS must address ballast water management, report on the adequacy of ballast watermanagement plans, include an assessment of compliance with current and anticipated stateand federal regulations, and identify and require specific actions that should be taken toeliminate the threat posed by ballast water discharges.Like all of the potential project impacts, the analysis of ballast water impacts should specificallyconsider environmental justice and cumulative effects.Lummi Nation Scoping CommentsCorps Project Ref. No. NWS‐2008‐260Corps Project Ref. No. NWS‐2011‐325January 201317