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APR-10-2000 1632 HES-MARATHON OIL COMPANY 713 296 3401 P.04 <br />• Page 2 <br />• April 10, 2000 <br />Technical Representation <br />Given the complexity of this project, it is impossible to provide "substantive" <br />comment during the comment period without benefit of technical representation. Speoifieally, <br />no individual has the lmowledgc or experience to enable them to "substantively" comment on <br />issues ranging from industrial sprawl, iniiastructure capacity, and air, water, lighting and noise <br />impacts. I have identified an environmental consulting firm that I recommend for this effort <br />They are F.II' & Associates (EIP}. I have enclosed one of their brochures for your review. I <br />have ao association with this firm ether than I am familiar with one o~f their principal <br />managers who would work on this project on our behalf. I have seen the outstanding quality <br />of his work and bave been impressed by the wealth of his experience in the preparation of <br />EIS/Envimnmcntal Assessment (EA) documents. For this reason, I sought his assistance in <br />this effort. <br />The EIS Public Comment period will last only 60 days. During this period EIP must <br />review and provide written comments on amulti-volume document that addresses awide- <br />range of potential impacts. The goal of EIP will be to address both the adequacies of the data <br />and the analysis presented. Sixty days is not a lot of time to accomplish this goal given the <br />complexity of the project. To facilitate this effort, it is proposed that ETP pnparc a Focused <br />EA document. 't'he Focused )rA document would represent an independent analysis of the <br />major environmental issuesrtnpacts associated with the project. This will facilitate their <br />response and provide empirical justification for comments that suggest the analysis in the EIS <br />is either inaccurate or incomplete. IrIP's Focused EA will only addresses theme <br />environmental issucs/impacts associated with this project. 1 have enclosed a copy <br />proposal for this effort for your review and comment. <br />EIP's estimated cost for the enclosed proposal is $218,000. T o date, I have a <br />commitment of $50,000 towards this effort There an also offers from other individuals <br />interested in contributing towards this eflbrt~pending the establishment of an official entity to <br />serve as the proponent for this initiative. Because the EIS is scheduled for release to the <br />"Public" this August/September, Iwould like to contract with EIP no later than May 1~` in <br />order to allow sufficient time for them to prepare the Focused EA. Preparation of the Focused <br />EA by EIP wiU take approximately three months. <br />Rationale for participation <br />Retention of a technical consultant on behalf of the Bay Axes Communities will <br />enable them to submit to the COE comments on the E1S that are technically justifiable and <br />thereiine have the opportunity to affect a change in the project It will also lay the legal <br />groundvwrk, as specified in the regulations, if it later were determined necessary to challenge <br />the project in court. In fact, failure to participate during the "Public" comment period <br />prohibits a Cominunity from challcngir~ the project in court. Also, by not participating <br />dueng the comment period, the surrounding communitles will allow entities whose irrterest do <br />not coincide with thcus to detennine the fate of the project including the impact W the <br />surrounding communities. <br />Finally, the EIS process is a regulatory process that cannot be impeded by anyone <br />even elected officials. While it is always a good idea to express one's views to elected <br />TOTAL P.04 <br />