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Goose Lake is 26 miles long and 9 miles wide, extending from south central Oregon and into northeastern California where the two meet with Nevada. The lake used to support an endemic form of redband trout that act like ocean going salmon, growing to giant proportions and migrating up the streams that feed it. Goose Lake has been dry in recent years and a run of these endangered fish hasn’t occurred since the early 1990s. Thankfully, they still exist in mountain streams.

The Warner Mountains form the east shore of Goose Lake, a narrow 70 mile long range in places over approaching 10,000’. Heavily forested, the range is the meeting place of three bioregions – the Great Basin, Sierran, and Cascadian – creating a unique mix of flora and fauna, many endemic. Its unique biology, geology and feel, an abundance of academics well know.

The archeological record indicates peoples have lived in the area for almost 15,000 years and the number of cultural sites and resources unparallelled in the United States – even compared to the southwest. Petroglyph panels 2 miles long and 40 feet high with figures taller than most men. Over the last few years, law enforcement has closed many of the large recently dry lake beds in the region because of looting.

Since contact, the area has been heavily logged and grazed – even irradiated from uranium production – but is recovering. With a population density averaging one person per mile, the potential for large scale wild lands protection for the many threatened and endangered species in this sea of blue sky, sage, antelope and juniper is among the best in the country.

The Project

The Department of Defense is subsidizing Red Rock Biofuels, of Ft. Collins, Colorado $75 million to annually create 18 million gallons of highly volatile jet, naphtha (white gas), and diesel fuel from forest biomass in the town of Lakeview, Oregon. The Environmental Assessment for the project, whose public comment ends February 5, 2016, is site specific and does not address regional cumulative environmental and social impacts.

The project site is in the 100 year floodplain of Goose Lake. Like the Malheur National Wildlife Refuge, Goose Lake is one of many critical stops on the pacific flyway. The fuels will be sent to market via a derailment prone railway whose tracks follow the shore of Goose Lake into California and along the North Fork of the Pit River, a tributary of the Sacramento. Critically, the tracks are one hundred feet from the front door of members of the XL band of the Pit River Nation, and any spill would devastate their agricultural lands.

The proposed facility site contains hundreds of cultural artifacts dating back thousands of years, including the very high potential of human remains. Red Rock and the State Historic Preservation Office of Oregon have an agreement, saying all artifacts are the property of the owner. Neither the State nor Red Rock have agreements with the Klamath, Piute and Pit peoples who, after consultation, oppose the project.

Emergency, water and sewer services for the project will be born by the citizens of Lakeview and project proponents will be given 15 years of local tax credits. There is no Emergency Response Plan to respond a catastrophic event at the biofuels facility that would require an evacuation of 2,500 people or for a potential derailment along the railway that includes the XL Pit and nearby town of Alturas, California (pop. 2800).

One hundred miles from nowhere, Lakeview has some of the worst fine particulate / PM2.5 pollution in the nation – a nasty air pollutant the lodges deep in the lungs and causes long term and debilitating damage, especially for the elderly. Over the years, EPA has strengthened the National Ambient Air Quality Standards for particulate matter due to the abundance of scientific literature regarding the negative health effects of PM exposure and its costs to society.

Environmental groups petitioned the EPA to redesignate Lakeview as nonattainment under the Clean Air Act and denied it just before the release of the environmental assessment. The rejection was based on a voluntary quid pro quo program that has not received formal rulemaking called “Advance,” the result being people in the community are fined for burning in their woodstoves while Red Rock is allowed to pollute without Best Available Control Technology on their refinery stacks, along with a watering down of the Congressional intent of the Clean Air Act.

Of national importance, Advance applies to all NAAQS constituents, a program that could be coming to a neighborhood near you.

Unidentified Appetite

The project requires a great deal of forest biomass over its lifespan and would not be built without an assurance that the supply would be available and constant. This supply cannot possibly be met though Red Rock’s association with the Collins sawmill alone. An Oregon company, Collins is heavily invested in biomass, involved in several projects including a large facility in Chester, CA and another currently being proposed Humboldt County. It requires resources from federal lands to be viable.

The project borders three states. Using a 75 mile radius, the Fremont-Winema in Oregon and Modoc National Forest in California are at risk. As are the Hart Mountain-Sheldon National Antelope Refuges in Oregon/Nevada and the Modoc National Wildlife Refuge in California. There are also three large BLM districts in three states.

This complicates things, as each department, bureau, region and state has their own policies and initiatives, their own legal mandates, and all too often they are incongruent with regional land use planning and coordinated response to proposed projects. This project has immense regional forest and land use implications.

Since the project will require forest biomass from federal lands, it is incumbent upon the federal lands management agencies work cooperatively and create a stand alone forest supply assessment for the 20 year lifespan this project. At a minimum, DoD/Red Rock needs to release their own private supply assessment that must have been developed for the project.

Bringing Home the Bacon

Although justified for national security purposes by DoD as diversifying its fuels portfolio, it is also justified from a private sector business perspective.

Red Rock and their financial investment firm backers Flagship Ventures will utilize federal subsidies designed for renewable energy and enter into guaranteed contracts with the DoD. It is a no lose money making operation. For additional profit, they have entered into agreements with Federal Express and Southwest Airlines so that these businesses can claim they are “green” for public relations purposes.

From the political perspective, Sens. Ron Wyden and Jeff Merkley, and Rep. Greg Walden all see biomass energy as a return to pre-Northwest Forest Plan employment.

Wyden uses his influence via the Senate Finance Committee to gain subsidies for the biomass energy and fuels industry. He is a leading voice concerning the funding of the USFS wildfire and pretreatment activities – well funded jobs projects in the wildland/wildland interface – and the USFS itself is involved in yet another dubious “collaborative” effort like the failing Four Forest initiative in Arizona. He is vociferous in his support for biomass energy.

Along with a good many timber state Democrats in the Senate, Merkley says he supports a secession of drilling for oil in the arctic while at the same time asking the EPA to consider biomass energy as renewable just before release of the Clean Power Plan. While the CPP did not look favorably regarding industry accounting claims that the forest to energy processes are carbon neutral, they did relent and allow each state to determine carbon neutrality for themselves and then justify it as part of the required Carbon Plans States must submit to EPA.

Walden, National Republican Congressional Committee Chair and former Chair of the Resources Committee currently held by Land and Water Conservation Fund opponent Utah’s Bob Bishop, promotes the recently released Utah-based Koch American Lands Council campaign that criticizes the federal government over the severe 2015 fire season, calling for an increase in grazing and logging as a way to reduce the risk. He said as much responding to the Malheur standoff and watch for him to flex his political muscles with the Red Rock project.

From a local economic perspective, for decades Lakeview and Lake County have been promoting forest biomass to energy projects as part of their economic development goals. It almost goes without mention the town wants the jobs associated with any industry.

Jane O’keefe is a former County Commissioner who started the working landscapes pseudo-environmental group Sustainable Northwest that promotes and provides a sheen of “environmentalist” cooperation to cover for these forest to biomass projects throughout Oregon and the Northwest. A Wyden staffer helped her get it started in the 90s. She is now a board member of the Oregon Environmental Quality Commission.

Secretary Sally Jewell works with area rancher and Oregon Cattlemen’s Association President John O’keefe, the husband of Jane, promoting Department of the Interior subsidized forest treatment programs and their “benefits” to sage grouse, cattle forage and riparian restoration. His vocal public cooperation with the Department of Interior is a large reason the listing was not granted.

There is economic and political institutional inertia at work, and proponents already lost a biomass to electricity project in 2015 that was to be developed by international renewable energy giant Iberdrola Renewables in Lakeview. They do not want to lose Red Rock.

A parable for proponents, the White King and Lucky Lass Mines are insecure Superfund sites contaminated by uranium that sit 20 miles northwest of Lakeview in the Fremont-Winema National Forest. The ore was taken into Lakeview where a processing mill operated for a total of 2 years, creating a radioactive plume of groundwater working its way south under the industrial district, to town and eventually Goose Lake. One of the reasons the Iberdrola project failed is they couldn’t build on their site. It is contaminated by the future-past promise of jobs.

Bait and Switch

Red Rock wants natural gas to drive their processes. They intend to use natural gas to heat a vessel containing forest biomass that is closed to the atmosphere and heated, the resulting gasses captured and refined into biofuels. They can also use natural gas to heat a vessel of natural gas to refine into fossil fuels in the case of supply disruptions, which means biomass feedstock.

Here we have a potential bait and switch, where subsidies gained under a now outdated biomass carbon neutrality ruse result in switching entirely to producing fuels from fossil based inputs. Although Oregon DEQ did require an analysis of the option, there is no mention of it in the DoD EA much less a model and discussion of the entire carbon cycle.

Without a Forest Supply Assessment, we cannot possibly know feedstock anticipated supply or disruption. By relying on individual agency NEPA sale or treatment documents instead of a formal supply assessment to provide feedstock, we absolutely know that disruptions are likely to occur based on litigation alone.

Don’t Let it Happen

Citizens shouldn’t be fined while DoD backed businesses are allowed to pollute. EPA must not be allowed to negate Congressional “rigidity” of the Clean Air Act through an internal program created without formal rulemaking that has the potential to affect all National Ambient Air Quality constituents – and by extension the communities that rely on “non-attainment” designations to protect citizens and the larger environment from the greed of corporations.

It is morally wrong that indigenous peoples ancestral lands are proposed to be pillaged once again and against their will. Through forest clearing and site development, a systematic looting of their cultural resources is about to begin.

These peoples have a right to the possessions and remains of their ancestors. They have a right to reject bomb trains at their front doors, and to ensure emergency response plans are in place to respond to physical and environmental threats to their safety and future viability.

The largest remaining contiguous old growth forests remaining in the continental United States are western dryland, juniper and pinyon forests. These trees reach thousands of years in age and just because they may not have the stature of a douglas fir doesn’t mean they don’t deserve recognition and protection. If they are to die, let it be by natural fire regimes and not for cattle or carbon profits.

There is a potential for a bait and switch to natural gas to supply Red Rock’s feedstock and the public has a right to know how this affects long term carbon reduction goals. The EPA did not go far enough with the CPP regarding biomass energy and its negative carbon footprint and bowed to timber state politicians bringing home bacon. The bait and switch to an unending carbon supply of natural gas to create fossil fuels is unacceptable and needs equation. DoD through this environmental assessment should oblige the planet and provide that analysis.

Finally, the Lakes country of Oregon, California and Nevada are worthy of federal protection and should be managed in an eco-regional fashion similar to the Yellowstone and Gila. It is a special place like nowhere else in the nation. It contains some of the best large scale environmental restoration potential in our nation and in the sagebrush steppe to allow for unfettered natural processes to fuel the health of an already fairly healthy environment.

Instead of spending public tax dollars creating jobs projects logging forests for a DoD bait and switch fossil fuels project under the ruse that we are protecting sage grouse and reducing wildland fire potential, the health of citizens, their landscape, and the carbon load of the atmosphere would be better served by removing cattle and working intergovernmentally to formally protect it.

Public comment for Environmental Assessment for the Red Rock Biofuels project closes February 5, 2016.