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

Increased risk of hazardous material spills, climate change, ocean acidification, acid deposition,and other potential impacts of the proposed project have a direct, serious, and substantialeffect on the political integrity, economic security, health, and welfare of the Lummi Nation, itsmembers, and all persons present on the Reservation. These affects will preclude the abilityand/or interfere with the ability of the Lummi People to exercise their treaty rights to fishthroughout their U&A – these impacts will result in significant, unavoidable, and unacceptableinterference with our treaty rights and irreversible and irretrievable damage to our spiritualvalues if the proposed projects are approved.16 Potential Impact: Environmental Justice16.1 Issue Definition/Rationale:Executive Order 12898 of February 11, 1994 requires federal agencies to achieve environmentaljustice by addressing “disproportionately high and adverse human health and environmentaleffects on minority and low‐income populations.” The impacts of the project, both negativeand positive, on minority and low‐income populations must be analyzed. Environmental Justiceissues include potential impacts on the physical and natural environment as well as social,cultural, and economic effects of the proposed project. Based on the 2010 Census, the Lummitribal members comprise the largest low income, minority population in the area.16.2 Extent/Geographic Scale of EvaluationImmediate AreaLocal AreaRegional AreaGlobal AreaThe physical, natural, social, cultural, and economic impacts of each of the proposedalternatives on the Lummi people need to be specifically addressed.16.3 Significant Unavoidable Adverse ImpactsThe construction and operation of the proposed projects as described will have numerousadverse impacts on the Lummi Nation including impacts to: cultural properties/culturalresources, fishing, hazardous material and oil spill risk, instream flows in the Nooksack River,forage fish habitat, finfish and shellfish habitat, global warming, ocean acidification, acid rain,tribal economy, water quality degradation and the introduction of invasive species, storm waterquantity and quality, wetlands, geologic processes, and public health and safety.The adverse impacts of these two projects can preclude the ability and/or interfere with theability of the Lummi People to exercise their treaty rights – these impacts will result insignificant, unavoidable, and unacceptable interference with our treaty rights and irreversibleand irretrievable damage to our spiritual values if the proposed projects are approved.Lummi Nation Scoping CommentsCorps Project Ref. No. NWS‐2008‐260Corps Project Ref. No. NWS‐2011‐325January 201322