Exxon Seeks to Alter Scenic and Historic Hwy 12/Lochsa Route of Lewis & Clark

by jhwygirl

The sheer disregard that this proposal has for what is one of the more scenic drives and accessible recreational and prime fishing corridors in western Montana blows my mind.

There are so many things wrong with this proposal as it is now – a weak environmental analysis, prepared by Exxon, without any scoping. You can count on hearing more about that as I attempt to delve into the nearly 200 page (plus 12 addendums) document….by May 14th!

That’s right – public comment, which opened April 8th – closes on May 14th on a proposal to establish a permanent “High and Wide Corridor” from Lewistown Idaho, over and across Lolo Pass and 300 miles of western Montana on to Canada and Exxon’s oil tar sands in Fort McMurray in Alberta.

You can access the full Kearl Module transportation Project here, from MDOT’s EIS and EA public notice page.

I think we got lucky last winter, but how many trucks and 18-wheelers end up in the drink down there on the Idaho side? Because that road is so narrow?

Are they going to have to blast some of those cliffs to widen the road? Along what is a pretty darn scenic corridor?

Two pieces of equipment are expected to move through Montana every day for a year. 24-feet wide, 30-feet high, 210-feet long, and weighing up to 334,568 pounds.

Do you recreate Lolo Pass? I do in the summer. Several times a week….and then with occasional weekends. Imagine the delays! They say 15 minutes? No frickin’ way – not with stuff as largw as what they’re proposing to move.

Of all choices, Lolo Pass was best? Well, guess what? We really don’t know – the environmental review done by Exxon included four alternatives: four Canandian highway routes and one US Interstate route. Those 4 alternatives? Dismissed in four paragraphs with no analysis of the so-called impassable barriers, while the Idaho/Montana route is extensive in the number of turnouts needing to be constructed, the number of small bridges needing crossed, and the extent of modifications needed to complete the route.

That was before Exxon tried to say that this project was “categorically excluded” from analysis.

In some circles, this is called a “pre-determined analysis of the preferred pre-chosen alternative.”

It’s bad enough when they don’t scope the thing to first see what types of alternatives come from the public…but when they don’t even bother to fully analyze the alternatives, well, folks, that’s just about bordering on violating some of our Montana Environmental Policy Act laws and rules.

ARM 18.2.251 requires a programmatic analysis “whenever the agency is contemplating a series of agency-initiated actions, programs, or policies which in part or in total may constitute a major state action significantly affecting the human environment,” and “whenever a series of actions under the jurisdiction of the agency warrant such an analysis as determined by the agency, or whenever prepared as a joint effort with a federal agency requiring a programmatic review.”

Did I mention that last July, MDOT Director Jim Lynch testified before the joint legislative Revenue and Transportation interim committee of the large impacts of this proposal? He said that the very nature of the project required an EIS..and yet, despite that testimony, MDOT chose to direct Exxon forward with an environmental review that didn’t even include scoping (a process in which initial outreach is made to the public for comments in an effort to determine alternatives and the scope and scale of analysis. Here is a link to Director Lynch’s presentation to the committee

You can watch the July committee hearing here. Lynch’s testimony starts about 18 minutes in. You can also review the minutes here.

What to do? Email MDOT public comment saying that the scope of this project requires a public scoping process to better assess alternatives; that all alternatives should be fully any thoroughly analyzed equally; that potential risk to important fisheries and other natural resources must be taken into consideration and weighed against other alternatives; that an assessment of risk to the public along what is a narrow secondary route used primarily for recreation should be considered; and that consideration of permanent impacts to scenic and historic corridors should be afforded the maximum protection necessary for future generations.

Just wait ’til I get to the economic impacts (or lack thereof) of having these things shipped nearly whole, after assembly in North Korea or China or wherever….

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  1. JC

    Sounds like we need to get some groups interested in nuking this project to get some standing. Then sue the hell out of the bastards once they release the decision on the EA until they cry uncle and go elsewhere.

    Western Watersheds Project, you listening?

    My first thought is that if they are doing separate EA’s in the different states, that amounts to a major NEPA violation. It is a form of piece-mealing that is intended to avoid looked at the whole picture. And if what Bob Gentry says pans out, then opening a corridor for future transportation needs to have future actions examined, also.

    This thing needs to go out for a full blown EIS that includes the whole project corridor in the U.S., and has true alternatives examined, like manufacturing the parts in the U.S. in Great Falls.

    Folks, demand a full EIS as part of any comments you may make. Demand that scoping occurs before a draft is released.

    • You raise an interesting thing that is banging around in my head – here in Montana, they are doing MEPA – Idaho has no such requirement….but – where is the NEPA? Shouldn’t there be a NEPA, when you consider that MDOT works are funded by Federal Highway Transportation dollars? That alone should e kicking off a NEPA review.

      NEPA is a stronger decision document (v. MEPA, which the state likes to use as a guidance document, something that sometimes falls short of that “clean and healthful” guarantee, if you ask me..) – so I’ve been kinda wondering that myself as I just begin to delve into this.

      • JC

        This thing needs to be kicked up to a full-fledged NEPA process with a full EIS covering the whole route, and with alternatives other than just route selection.

        There are a whole bunch of connected actions involving federal agencies (multi-state travel,including waterways) and states that need to be examined.

        This project cries out for an interagency approach utilizing NEPA and a full EIS. I imagine the threat of a lawsuit against the EA may help push that decision along. I’ll do some checking to see what may be in the works.

  2. James Conner

    After reading the EA, I can understand why the route was pushed so far south. The only way to move the stuff across Canada is to dangle it from a balloon.

    The crux of this issue is the decision to build the modules in Korea and ship them thousands of miles across the Pacific, and then inland a third of the distance across North America, instead of building them in Alberta. The oil companies have succeeded in exporting the manufacturing issues to Korea, and most of the transportation issues to the United States.

    I think the probability of an accident that causes significant and lasting damage to the environment is low, but the risk is a risk that would not exist if the modules were being built in Canada.

    I usually take the scenic route along Highway 12 when I head west to Oregon, but I’ll be driving the freeway on the days when these loads are laboring up the grade and around the hairpins farther south.

    • Bob Gentry

      Interesting point on the alternatives analysis here. It is very difficult for me to conclude that the facilities encountered along the Canadian routes are impassable given their cursory treatment in the EA. A single two or three sentence paragraph for each, with no discussion of construction alternatives.

      Juxtapose that against millions in expenditures on MT highways necessary to get around obstructions on MT roads. A rational alternatives evaluation, undertaken according to the spirit and letter of MEPA, would have looked at the cost of construction measures necessary to bypass obstacles along all of the routes. That would have allowed for a real comparison of the impacts, adverse and beneficial, of the alternatives and allowed a decisionmaker to make an informed decision. MEPA is law that requires state agencies to “think before they act.”

      Second, if the Canadian routes are truly impassable, then the EA fails to consider ANY alternatives (and thus fails to comply with MEPA). MEPA requires MDT to include in the environmental review a “description and analysis of reasonable alternatives to a proposed action whenever alternatives are reasonably available and prudent to consider and a discussion of how the alternative would be implemented.” If there were no alternatives available, the document should have stated this up front, though that would have been an easily challenged statement that MDT did not want to defend.

      The entire alternative route discussion in the EA begs the question, why did MDT not consider what has been called the “traditional route?” They purport to consider routes that enter different ports in Canada and follow highway routes outside of Montana. Why did they not consider the fact that oversize modules for the tar sands are regularly shipped from Korea to Alberta via the Port of Houston, TX? The distance, cost, and issues associated with the Houston to Alberta route are well known, and it would have been an easy analysis to weigh the impacts, beneficial and adverse, of using an existing route vs. creating a whole new route over mountain passes, along scenic river corridors, and along the small highways and through the small towns along the Rocky Mountain Front.

      An analysis of the cost of dangling it from a balloon to bypass obstacles would have been somewhat more in line with what is required under MEPA for an alternatives analysis. But they didn’t even do that. See the problem?

      But this is only one of several problems with this document – all of which so limit the scope of review of the environmental impacts of the proposal to create serious questions regarding MDT’s compliance with MEPA in this document.

      • Wouldn’t it be ironic if this Lewiston Port route was cheaper because of bringing the things that far up the waterways first?

        Maybe fuel prices make it too expensive to take more traditional routes – so it’s cheaper to blast some cliffs, widen some highway, stress local bridges and roadways and impact the off-route travelers who are taking those routes just because they want to avoid stuff like this.

        • carfreestupidity

          Its not ironic if its true. Shipping something over a waterway is the cheapest form of transportation when it comes to moving bulk… and this things is certainly bulky.

          Thats why its coming all the way from Korea… MONEY! Cheap labor and energy inputs, cheap transportation across the ocean all the way up to Lewiston.

          And I can understand why the Canada route would be out… there would easily be over half-a-dozen passes that thing would have to go over that are pretty large.

      • James Conner

        Put a string on a globe and trace the great circle routes. Then trace the distances from Astoria along the proposed route and from Houston to the tar sands. The over the Rockies route requires both a shorter drive and a shorter steam across the Pacific. That saves fuel costs and the cost of transiting the Panama Canal. That’s why the northern route was chosen.

        Bob is right that the MDT document is cursory, but a more detailed analysis probably would confirm the findings that the Canadian route is impractical. Given the disruption this haul will cause, I can’t think of a single reason why the MDT would want the loads traveling through Montana, and therefore I think the department would try to find a way to argue that the trans-Canada route is practical.

        But I certainly endorse a more comprehensive analysis, one that includes building the stuff in Alberta as a viable alternative. And yes, I’d examine the balloon dangle option, although that seems like a terrible waste of helium.

  3. Who is the hammer here? That is what I don’t understand. If MDT Director Jim Lynch is testifying before the very legislative body that provides in-depth oversight to his department that a full Environmental Impact Statement is needed, why is now relegated to a relatively unsupervised environmental analysis done by the applicant themselves?

    Someone’s pulling the strings there. If it’s the feds, it’s clearly another indication that NEPA is needed. If it’s someone in our own government, then I want to know who is telling our MDT Director to pull that that analysis back and try and float a mere basic environmental analysis, that is – as I’ve alluded to, just as Gentry does – inadequate and incomplete?

    When federal dollars are used – as they are to maintain these routes, money that is distributed to MDT for that very purpose – then NEPA is required.

  4. klemz

    This seems inconceivable. They’re going to lug those trucks over Lolo Pass, down the narrow two lane along the Lochsa to Kamiah, along that equally narrow corridor past Kooskia and Orofono and up and over that ridiculous grade east of Lewiston? Are you kidding?

    • JC

      You’ve got it backwards. They are offloading the equipment at the Port of Lewiston, and hauling it up highway 12 over Lolo Pass and through Missoula, down MT 200, and then up to Canada.

  5. mhwygirl

    so glad to see people confronting this issue.
    my question is why are we (America) letting Exxon Mobile jeopardize our National Wild and Scenic River corridor so they can save money – money we the taxpayers will most likely be subsidizing. . (Idaho is seeking $11 million from the feds to upgrade the port of lewiston to make this project and future ones like it possible. . .full article; http://voices.idahostatesman.com/2010/04/21/rockybarker/shipping_huge_mining_equipment_planned_through_lochsa_corridor )

    THere is another route – the traditional route for these kinds of shipments -here’s what i read in the missoulian:
    One such alternative, Gentry said, is the “so-called traditional route” through the Gulf of Mexico and Houston, “the route by which this equipment has been getting from Korea to Alberta for a great amount of time.”Gentry said the proposed route through Montana will save the oil companies money by cutting 5,300 nautical miles and 1,400 road miles off the traditional route, according to WashingtonPorts.org.
    – here’s the link to the full article
    http://www.missoulian.com/news/local/article_94f01140-4cf6-11df-aa4e-001cc4c002e0.html

    maybe if we show Exxon that it will cost them more money to change the route than any savings they would gain by saving on nautical and road miles they will drop the project themselves.

    thanks for all your time and energy on this issue!

  6. Michael Gehman

    To stop the big rigs, occupy the turnouts. Imperial Oil stated at the Meadow Hill meeting that a rig will not leave a turnout until the next turnout is clear. Thus, to stop a rig all that need be done is to occupy (with bikes, tents, picnicers, cars, whatever) a turnout in front of it. It’s not clear to me that this would be illegal. Presumably use of public turnouts is on a first come, first served basis. If only a few people all along the route were willing to deploy this tactic the rigs would be seriouly inhibited.

    Preferably, a credible threat to deploy this occupation tactic would induce Imperial Oil to abandon the route ahead of time. But even if they proceed, I think disrupting the operation by means of turnout occupation would be a worthwhile thing to do.

    • JC

      Hehe. Sweet!

      What’s the highway or sheriff going to do? Allow Imperial Exxon to privatize the turnouts? Get the state leg or county commissioners to pass some stupid law giving priority to the rigs?

      Someone should start an online signup campaign to host get togethers on the various turnouts on the lower Lochsa/Clearwater River.

      • Michael Gehman

        If only one turnout is occupied Imperial Oil might choose to violate its policy in this instance and drive past it to the turnout beyond. To forestall this maneuver it might be necessary to occupy two or three consecutive turnouts at a time.

  7. they get away with this and they will be hauling oil down the corridor next…..after all its now a “industrial corridor”.Good Job America.Ps ,its my latest understanding that exon will be “privatizing” all turnouts making them inaccessible to recreationists?

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