Submit Comments on Dredging in Coos Bay


Even though we’ve defeated the proposed PCPL Pipeline and Jordan Cove LNG Export project twice, Veresen is trying for round 3 and submitted their official project application to the Federal Energy Regulatory Commission last week. FERC will likely accept their application as complete in the next week which will kick off a number of state and federal permitting processes and opportunities for action.

You can help take action to stop the PCPL fracked gas pipeline and LNG export project now by  submitting comments to the Army Corps of Engineers about dredging in Coos bay. The Port of Coos Bay is seeking permits to significantly deepen and widen the bay for facilitating export projects including (if not exclusively) Jordan Cove LNG. The project would be funded in part by $60 million state grant, meaning taxpayers would foot the bill for a project that would largely benefit a Canadian corporation.

Here's some more information on how to submit comments and some helpful talking points that you can raise. Comments are due no later than Tuesday October 3rd, 2017.

Talking Points for Writing Comments to the Army Corps on the Port of Coos Bay Dredging Project

Background: The U.S Army Corps of Engineers is preparing an Environmental Impact Statement (EIS) to analyze the potential environmental effects of approving a major dredging project on the Bay. The project proposes to widen and deepen the Coos Bay Federal Navigation

Project from the ocean to river mile (RM) 8.2 to so that large tankers can fit in the bay to transport the LNG overseas. The Army Corps is looking for comments on what issues to cover in their Environmental impact Statement. We can raise issues on everything ranging from navigation concerns, socio-economics, fish and wildlife, water quality, safety, shoreline erosion and accretion, recreation, and cultural and historic resources and more. Scoping comments will also be used to develop possible project alternatives.

Submitting Comments: All interested parties are invited to submit written comments on or before October 3, 2017 to the U.S. Army Corps of Engineers, Portland District (PM-E), P. O. Box 2946, Portland, OR 97208-2946, or by email at All comments should include “Coos Bay Channel Modification Project EIS”


  1. Project purpose: The Public Notice for dredging does not state the reasoning for channel modification (e.g. they don’t say it’s for Jordan Cove even though it’s pretty clear the project would almost exclusively benefit that project)

  • In the Draft Environmental Impact Statement (DEIS), the Corps must demonstrate why it is necessary to widen and deepen the channel, and whether that purpose can be met without modifying the Coos Bay Federal Navigation Channel. This should also include evaluation of the types and numbers of shipping projected for Coos Bay.

  • The Corps has not stated a clear purpose for the widening and deepening of the Coos Bay Federal Navigation Channel.

  • The US Army Corps of Engineers must clarify purpose of the dredging request

2) This is a connected action to the Jordan Cove LNG Export Project

  • There is a very similar proposal to dredge the channel, dispose the dredged material offshore, and increase access for ship traffic for the Jordan Cove LNG Export Project.

  • The Corps should do a full review of the direct, indirect, and cumulative effects of modifying the channel and disposing of the dredged material offshore in the context of the proposed LNG terminal and Pacific Connector Pipeline as a connected action.

3) Public Trust: This impacts our public trust right of fishing, access, and water use.

  • Being able to use and access waters for fishing is one of our most basic public trust rights in Oregon (According to the case: Oregon Shores Conservation Coalition v. Oregon Fish and Wildlife Comm’n, 62 Or App 481, 493 (1983))

  • Modifying the channel will have significant impacts to fishing and shellfishing areas within Coos Bay. This would negatively impact the economic value of fisheries in the area.

  • Modifying the channel may interfere with the ability of the public to access these areas for fishing and other general water uses. This would negatively impact the outdoor recreation industry in the area.


4) Extent and Impact of Channel Deepening: EIS should consider the direct, indirect and cumulative impacts to the estuary

  • The proposed dredging and disposal associated with the channel modification will likely cause direct, indirect, and cumulative impacts to the estuary, including impacts to fish and wildlife, vegetation, water quality, geomorphology, and tsunami risk.

  • The EIS needs to consider the direct, indirect, and cumulative impacts of the proposed dredging:

    • The EIS should consider how widening and deepening the channel could change tidal dynamics, alter the bottom of the estuary which is important habitat, and increase tsunami hazard.

    • The EIS should consider impacts to water quality from dredging and disposal, including but not limited to dissolved oxygen, salinity, temperature, fecal coliform, and sediment contaminants.

    • Since the dredging could destroy important habitat for fish, oysters, clams the EIS should consider the biological impacts, including but not limited to benthic organisms, fish, marine mammals, and invasive species.

  • The Corps should determine whether this project has the potential to violate the Oregon water quality standards for dissolved oxygen and sediment.


5) Coastal Zone Management Act: The State of Oregon must be allowed to determine   if the project complies with the Coastal Zone Management Act.

  • The Department of Land Conservation and Development has the authority to review federal permits that require federal consistency review.

  • The Corps cannot issue any permit until the State of Oregon determines if this proposed project is consistent with the Oregon Coastal Zone Management Act.

  • The EIS and Department of State Land Conservation and Development have to demonstrate that the proposed project is in compliance with Statewide Planning Goals, city and county land use plans, and state policies for water quality, removal-fill, fish and wildlife.

  • The Corps should consider their compliance with the Oregon Coastal Zone Management Act by evaluating:

    • Impacts to coastal shorelines, estuaries and dunes under Statewide Planning Goals 16, 17, and 18,

    • Impacts related to natural hazards under Statewide Planning Goal 7,

    • Impacts to natural resources, air, and water under Statewide Planning Goal 5 and 6,

    • And requirements of state statutes and regulations about removal-fill, water quality, and fish and wildlife protections.

6) Socioeconomic factors

  • What impacts will dredging have to fishing, crabbing and oyster industries in the bay?

  • How will the project impact travel related to fishing, recreation and tourism?

7) Who Pays?

  • Will the Port of Coos Bay be using public, taxpayer funds to develop the project? If so, how much of the total cost is projected to be paid for by private companies.

  • What companies stand to benefit the most from the project? What companies stand to be negatively impacted?

8) Climate Impacts

  • The Corps should consider the how widening the channel may increase traffic from large tankers and the climate impacts of increased traffic in the bay.

9) Alternatives

  • The Corps should rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.

  • Devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits.

  • Include reasonable alternatives not within the jurisdiction of the lead agency.

  • Include the alternative of no action

September 26, 2017 at 6pm - October 04, 2017
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