DEIS Comment Camas Alternative 3

Camas Earth Day Society DEIS Comments deficits plaguing local governments this should be an element of impact analysis. Strong Towns has called this “America's Growth Ponzi Scheme.” 3 Consideration of Alternatives . The County is required by the GMA and SEPA to consider alternatives to the proposed action. CEDS maintains that the City of Camas’ refusal to consider even a portion of the Georgia Pacific Camas Mill’s 660-acres of downtown waterfront property, o ffi cially designated “non-operational” is not consistent with an alternatives analysis. Making this more relevant is the Agreed Order between the landowner and the State of Washington. This agreement specifies that a substantial portion this mill property is subject to cleanup order under the Model Toxics Control Act (MTCA). CEDS believes that pursuant to GMA policies, including new housing a ff ordability and climate change requirements, the mill property must be considered as an alternative especially when significant expansions to a UGA into rural landscape are proposed. “Revitalization” and “Current and Long-Term Operations.” Camas has been abuzz in the last few weeks with a significant milestone in the history of the mill property. The demolition of the Kraft Mill/Bleaching/Boiler Recovery facilities and removal of the substantive buildings and above ground infrastructure makes the soil and groundwater better available for investigation. The City of Camas terms it “multi-year revitalization project. ” 4 A suggestion has been made to the Camas Mill Cleanup Community Advisory Group (CAG) concerning “Interim Actions” and their authority under Washington law. An Interim Action is a process within the MTCA that focuses on a specific problem or area for investigation and cleanup on an accelerated schedule. What can constitute an Interim Action? Per the Agreed Order, Interim Action is an action “that is needed to provide for completion of a site hazard assessment, remedial investigation/feasibility study, or design of a cleanup action plan. Either party may propose an interim action under this Order.” The Kraft Mill/Bleaching sites, and perhaps the Recovery Boiler, could have consideration for interim actions. This would allow the independent investigation of these large formerly complex industrial areas without being tied to some of the more complex issues involving wetlands, Columbia River and interrelated natural systems. The Kraft Mill site, and more so with the others, open large areas that can link the lab site to Camas' historic downtown. With prior demolitions it provides a physical reconnection to the river and highlights the importance of the cleanup issues raised by the Yakama Nation and Columbia Riverkeeper.

https://www.strongtowns.org/journal/2020-5-14-americas-growth-ponzi-scheme-md2020 3 https://engagecamas.com/georgia-pacific-camas-mill-revitalization-project 4 November 29, 2025 Page 6 of 11

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