Friday, December 14, 2012

Coal: Bellingham's GPT Scoping Comments

Here is the text of a letter the City of Bellingham intends to submit as its latest comprehensive GPT EIS Scoping Comments:

December 12, 2012

GPT/Custer Spur EIS
1100 112th Avenue NE Suite 400
Bellevue, WA 98004

RE: Scoping Comments for the Gateway Pacific Terminal Environmental Impact Statement

Dear Sir or Madam:

These scoping comments are submitted to you on behalf of the Mayor of the City of Bellingham and the Bellingham City Council.  The following comments are meant to address both on and off-site potential impacts of the Gateway Pacific Terminal (GPT) project to the City of Bellingham and its Urban Growth Areas and are organized according to the negative impacts the project may have on the City's Legacies and Strategic Commitments, as further discussed below and attached for your reference.

On July 23, 2012 the Bellingham City Council adopted Resolution 2012-22, which is attached to this letter. The Resolution highlighted the potential that additional off-site infrastructure within the City may be necessary for the GPT project to function as proposed at full-build out in 2026, which may adversely impact the City's ability to achieve its Legacies and Strategic Commitments.

Therefore, the City is providing the following specific scoping comments for consideration and inclusion in the Final Scoping Document in order to inform the various alternatives to be studied in the EIS.
1.   Please analyze the cumulative impacts of all currently proposed coal export facilities and/or dry bulk commodity terminals within Washington and Oregon in a Cumulative Impact Analysis pursuant to the National Environmental Protection Act. Specifically, please analyze the cumulative impact to existing freight and passenger train traffic capacity in Washington State as well as the cumulative impacts to natural and cultural resources resulting from the increase in freight train trips within Washington State and vessel traffic within Puget Sound, Georgia Straight and the Columbia River.  We acknowledge that the BP Refinery located within the Cherry Point Industrial Area has applied for permits to develop new railroad (loop) infrastructure on their own property. The proposed improvements are intended to accommodate a planned for increase in trains carrying crude oil from the Midwest to their facilities at Cherry Point. BP has forecasted that they expect one additional train every two days to travel on the BNSF line traveling through Bellingham to the Custer Spur and then to the refinery itself. Please include this additional train traffic in the Cumulative Impact Analysis. 
2.   Please analyze the increase in impacts to the health and welfare of the citizens of Bellingham including impacts from diesel emissions from trains and ships, coal dust, noise and the potential for increased rail/car and rail/pedestrian accidents through a comprehensive independent third party Health Impact Assessment. 
3.   Please analyze the impacts to existing freight train and passenger train service, including impacts to shared capacity by the addition of up to 18 additional bulk-commodity train trips per day on Burlington Northern Santa Fe (BNSF) railroad infrastructure (Bellingham Subdivision Mainline), between Mount Vernon, Washington and the GPT. 
4.   Please analyze the impacts to the elements of the environment, as specified in WAC 197-11-444, which would result from the construction / development of a new railroad siding partially or wholly within the City in order to facilitate / accommodate the addition of up to 18 additional bulk-commodity train trips per day on the Bellingham Subdivision Mainline (BSM) between Mount Vernon and the GPT. 
The following comments relate to the City's potentially affected resources and are categorized in relation to the City's Legacies and Strategic Commitments. The City expects these resources to be adversely impacted by the increase of up to 18 additional freight train trips traveling through the City of Bellingham every day at the time of full build out of the GPT. We request that the "increase" in impacts resulting from this action be analyzed through the EIS process for each element list below.
  1. Please analyze the increase in impacts within an EIS to the following elements, related to the City's "Healthy Environment Legacy," which commits the City to protect the health of Bellingham Bay and its ecological functions, as well as reduce contributions to climate change:
    • Marine species, vegetation and the water quality of Bellingham Bay and its pocket estuaries as a result of increased coal dust from open container cars and increased diesel particulates from locomotives;
    • Marine species, aquatic vegetation and water quality due to an increase in vessel traffic and vessel anchorage;
    • Air quality of park and recreation users related to increased dust and increased particulates from open container cars and locomotives due  to idling of those locomotives to the proximity of BSM to heavily used City park and trail amenities;  
    • Upland wildlife habitat, connectivity and accessibility to park lands and greenway habitat corridors as a result of an increase in the amount, frequency and length of commodity trains;
    • Air quality, the marine environment and upland vegetation, resulting from the various methods of handling, moving and storing coal and other similar commodities from the moment it arrives at the terminal via train to its deposition into the cargo vessel;
    • Marine near-shore environment from an increase in noise and vibration due to additional, longer and more frequent freight train trips along the BSM; 
    • Noise from increased train traffic on park users, riverine and estuarine fish and wildlife and related habitat; and
    • Potentially unstable slopes located on or adjacent to public and private lands especially those within the Edgemoor, South Hill, Birchwood and Columbia Neighborhoods as a result of additional, longer and more frequent freight train trips along the BSM; 
  1. Please analyze the increase in impacts within an EIS to the following elements related to the City's Legacy of "Vibrant and Sustainable Economy," which commits the City to support and promote a thriving local economy across all sectors, public and private investment as well as preservation of farmland and agricultural economy;
  • Existing and planned land use and economic development potential within the City's Central Business District, the Waterfront District, Old Town and Fairhaven, all of which have development potential west of the BSM as a result of additional, longer and more frequent freight train trips;  
  • Property values and assessments and the impacts to services resulting from a potential decrease in property tax revenue; 
  • Job retention and creation within the City of Bellingham;
  • Bellingham's economy from increased train traffic related to tourism use of public park property within proximity of the rail line;
  • Tribal nations, local and regional fishing industries resulting from the increase in vessel traffic and marine infrastructure within the Strait of Georgia and the Cherry Point Aquatic Reserve. 
  1. Please analyze the increase in impacts within an EIS to the following elements related to the City's Legacy of "Sense of Place," which commits the City to support and protect neighborhoods, historic and cultural resources, as well as natural settings and access to open space: 
  • Resulting from additional freight train trips on the BSM on recreation resources and social benefits of the Bellingham parks and open space system;
  • Impacts of additional, longer and more frequent freight train trips along the BSM, as well as related infrastructure, including fencing, signals, siding, tracking, to the quality of public parks, open space and trails, and to scenic water views;
  • Impacts of potential expansion of tracking or sidings associated with the increased rail traffic on public park lands and access to those lands, including impacts due to acquisition and/or eminent domain of properties that have a potential for future public access;  
  • Impacts of trains idling to adjacent park land, including public access, emergencies and operational access, noise, dust;
  1. Please analyze the increase in impacts within an EIS on to the following elements  related to the City's Legacy of "Safe and Prepared Community," which commits the City to preventing and responding to emergencies and crime, as well as increasing community readiness and resilience:
  • Paramedic response times and services of City of Bellingham's Fire and Police Departments as well as Whatcom Medic One and Fire District 7;
  • Emergency response times for Medic One and Fire District 7 paramedics within and beyond the northern portions of the City;
  • Safety of the general public resulting from  fire in a coal car, including idling locomotives and train derailments or collisions;
  • Impacts resulting from accelerated wear and tear on the rails themselves, ties, supporting ballast, bridges, crossings and tunnels.
  • Public access issues, including delays in emergency response time and operational access, caused by increased rail traffic, to existing and future park lands along the rail right of way;
  • Existing rights of way, both opened and unopened, that provide access to public lands and shorelines;
  • Public and private property resulting from any potential spill on land or water during transport, storage or handling, including any spill due to a ship collision. 
  1. Please analyze the increase in impacts within an EIS on the following elements related to the City's Legacy "Mobility and Connectivity Options," which commits the City to providing safe and well connected mobility options for all users as well as increase infrastructure for non-vehicular modes of transportation:
  • The safety of park users as a direct result of increased rail traffic.  Many existing legal access points to parks and trails involve at-grade rail crossings;
  • Mobility and connectivity between on-street and off street non-motorized pedestrian and bicycle systems;
  • Existing and proposed trail systems, including the Coast Millennium Trail, Bay to Baker Trail, Nooksack Loop Trail, all of which are identified in the City's Comprehensive Plan as well as proposed trail systems and linkages within and along the shoreline in the Waterfront District;
  • Crossing safety for pedestrians, bicyclists, transit buses, automobiles, and freight delivery vehicles;  
  • Traffic congestion backing up into other intersections, blocking access to side streets, alleys, and driveways;
  • Access to and from Amtrak passenger trains, the Alaska Ferry Terminal, other marine transportation tenants stationed at the Bellingham Cruise Terminal, the Community Boating Center and the Port of Bellingham's Fairhaven boat launch facilities and the effect on Bellingham's tourism income.
  • The following at-grade street crossings all within the City limits:
  • Harris Avenue (Fairhaven)
  • 6th Street north of Harris Avenue (Fairhaven)
  • Bayview Drive (Boulevard Park) 
  • South Bay Trail @ Boulevard Park
  • Pine and Wharf Street (Waterfront District)
  • Cornwall Avenue (Waterfront District)
  • West Laurel Street (Waterfront District)
  • Central Avenue (Old Town)
  • “C” Street (Old Town)
  • "F" Street (Old Town)
  1. Please analyze the following items related to the City's Legacy "Quality, Responsive City Services," which commits the City to delivering efficient, effective and accountable services, and transparent processes to involve stakeholders in decisions:
  • Associated costs of transportation improvements necessary to mitigate safety, congestion, and access issues resulting from an increase in freight train trips as part of the GPT proposal.
It is important to note that the City concurs with the October 22, 2012 letter from Buri, Funston and Mumford Attorneys at Law, which asserts that the GPT proposal is a "major development" as defined in Whatcom County Code (WCC) 20.88.010 and therefore is required to satisfy the "major development criteria," as specified in WCC 20.88.130.

As the project qualifies as a major project, the applicant is responsible for demonstrating   compliance with the criteria listed in WCC 20.88.130, including a showing that the project will not impose uncompensated requirements for public expenditures for additional utilities, facilities and services, will not impose uncompensated costs on other property owned and will be appropriately responsive to any EIS prepared for the project. 

It is vital that any off-site infrastructure that is necessary for the project be considered as part of the project proposal itself, as required by WCC 20.88.130(6).  If the Washington State Department of Ecology, the Army Corps of Engineers and Whatcom County (the "Co-Leads) does not require that the off-site infrastructure be considered as part of the project, then that infrastructure should be included as a condition precedent to the establishment of the major development, as required by WCC 20.88.140 or, considered as a reasonable alternative to the proposal and be analyzed pursuant to both SEPA and NEPA.  

The City looks forward to the inclusion of the study of these potential impacts as part of the GPT project EIS.

Kelli Linville Terry Bornemann
Mayor City Council President

Attachments: Legacies & Strategic Commitments
                    Resolution 2012-22

[Note: these two attachments are pdf documents which I could not figure out how to display here. 
They will be available on the City's website]
Recent published articles on Coal Export:

Coal train impacts feared along the Sound |

Seattle turns out to oppose proposed coal port |

More than 2,000 attend coal terminal hearing in Seattle | Cargo Terminal | The Bellingham Herald

EarthFix · Oregon Public Broadcasting

Coal-export hearing packed, mostly by opponents | Local News | The Seattle Times

Seattle PR firms are doing “coal’s dirty work”: study | Strange Bedfellows — Politics News -

Get Whatcom Planning

SEATTLE: Protests ahead of Wash. coal terminal hearing | Northwest News | The Bellingham Herald

Hearing on Gateway Pacific coal project draws hundreds in Vancouver | Cargo Terminal | The Bellingham Herald

Look Who’s Taking Coal Money | Sightline Daily

Coal ports are bad idea for both Washington and China |

EarthFix · Where Coal Divides, Community Remains · KUOW

Waterkeepers Join Thousands at Final Public Hearing on Proposed Coal Export Terminals – EcoWatch: Uniting the Voice of the Grassroots Environmental Movement

Debate over coal exports leaves out some communities along route, critics charge | Cargo Terminal | The Bellingham Herald

Ship crashes into dock at Westshore Terminals, spilling coal into water (with video)

Video: Sightline on Coal Exports | Sightline Daily

City calls on Port Metro Vancouver to delay coal export expansion | The Vancouver Observer

Planned Oregon coal export terminal would exceed pollution standards, Sierra Club charges |

Coal supporters make their push |

Coal backers hire temp workers to stand in line - - Dec. 4, 2012

Monday, December 10, 2012

Coal: GPT EIS Scoping Comments Summary

Another excellent article by Floyd Mckay appears today in Crosscut.
Here are the concerns I have submitted as GPT EIS comments to date:

Coal: GPT EIS Comment No. 31 Sunday, December 9, 2012 
Concerns Based on Reality

Coal: EIS Scoping Comment No. 30 Saturday, December 1, 2012 
Programmatic EIS Needed to Counter Applicant's Local PR Campaign

Coal: EIS Scoping Comment No. 29 Friday, November 30, 2012
Diminution in value of my home & other properties

Coal: EIS Scoping Comment No. 28  Thursday, November 29, 2012
Does GPT mean Gambling Public Trust?

Coal: EIS Scoping Comment No. 27  Wednesday, November 28, 2012
San Juan Islands National Conservation Area

Coal: EIS Scoping Comment No. 26 Tuesday, November 27, 2012
Tugs, Pilots, Spill Response & Rescue Vessels

Coal: EIS Scoping Comment No. 25 Monday, November 26, 2012
Non-reimbursed Government Expenses

Coal: EIS Scoping Comment No.24  Thursday, November 1, 2012
Proposed BNSF Bellingham Siding & Idling Track

Coal: EIS Scoping Comments No. 21, 22, 23 Wednesday, October 31, 2012
Liability Responsibility
Train Noise
Misuse of U.S. Coal Resources

Coal: EIS Scoping Comment No. 20 Tuesday, October 30, 2012
Loss of Use of Parks & Trails

GPT: EIS Scoping Comment No. 19 Friday, October 12, 2012
Tribal Concerns

GPT: EIS Scoping Comment No. 18 Thursday, October 11, 2012
GPT: The Liability Labyrinth Linchpin

GPT: EIS Scoping Comment No. 17 Wednesday, October 10, 2012
Impacts on Property Values, Taxes & Levels of Service

GPT: EIS Scoping Comment No. 16 Tuesday, October 9, 2012
Climate Change: Who's Responsible?

GPT: EIS Scoping Comment No. 15 Monday, October 8, 2012
Wasteful Water Use

GPT: EIS Scoping Comment No. 14 Sunday, October 7, 2012
Chuckanut Drive Landslide Hazard

GPT: EIS Scoping Comment No. 13 Saturday, October 6, 2012
Coal Dust Clouds?

GPT: EIS Scoping Comment No. 12 Friday, October 5, 2012
Purpose = Need?

GPT: EIS Scoping Comment No. 11 Thursday, October 4, 2012
Bulk Carrier Vessel Concerns

GPT: EIS Scoping Comment No. 10 Wednesday, October 3, 2012
Waterfront Redevelopment

GPT: EIS Comment No. 9 Tuesday, October 2, 2012
Financial Underpinnings

GPT: EIS Scoping Comment No. 8 Monday, October 1, 2012
Vessel & Rail Capacity & Congestion

GPT: Scoping Comment No. 7 Sunday, September 30, 2012
Safety & Levels of Service at Rail Crossings

GPT: EIS Comment No. 6 Saturday, September 29, 2012
Lake Terrell Wildlife Preserve

GPT: EIS Scoping Comment No. 5 Friday, September 28, 2012
Is GPT Appropriate For Cherry Point?

GPT: EIS Comment No. 4 Thursday, September 27, 2012
Vessels, Jobs & Cold-Ironing

GPT: EIS Scoping Comment No. 3 Wednesday, September 26, 2012
Corporate Structure & Responsability

GPT: EIS Scoping Comment No. 2 Wednesday, September 26, 2012
Scope of Project

Coal: Adding Insult to Injury Monday, September 24, 2012
Incomplete Application

Sunday, December 9, 2012

Coal: GPT EIS Comment No. 31

Concerns Based on Reality

Several recent events and actions lend credence to concerns by citizens, including these:
• The coal conveyor & access damage at the nearby Westshore Coal Terminal in BC resulting from a late night collision by a large Bulk Carrier vessel with a pilot on board.
• The railroad bridge collapse south of Bellingham on the BNSF main line used by heavy coal trains.
• The derailment of a coal train east of Tri-Cities, spilling 34 loaded cars.
• The protracted delays of traffic in Skagit County due to a stalled coal train with brake problems.
• The unseemly acts by the GPT Applicant to recruit allies to pack public meetings designed to gather citizen concerns.
• The repeated dismissals of legitimately expressed citizen concerns as only NIMBYism by GPT spokespersons.
• The ongoing media advertising campaign designed to influence public opinion during the 120-day EIS Scoping period, which advocates multiple coal terminals -not just GPT- which seems like a concerted effort on behalf of an entire industry. Doesn't that justify a programmatic EIS approach is necessary?

There is likely available statistical information on the frequency and severity of both large bulk vessel and coal train accidents. I request that this information be researched and applied to the rail and marine traffic projected by the Applicant for GPT.
Additionally, the costs to the natural environment, existing businesses, residents, governments services and facilities need to be ascertained for inclusion into the EIS evaluation.
A programmatic EIS appears necessary to include all of the possible impacts, whether to the GPT site or anywhere along the proposed transport routes.
It would also include impacts to the atmosphere, the oceans and inland waterways, the land, human health and impacts to each ecosystem likely to be affected over time.

Saturday, December 1, 2012

Coal: EIS Scoping Comment No. 30

Programmatic EIS Needed to Counter Applicant's Local PR Campaign

I am concerned with the constant, expensive, misleading and one-sided propaganda being promulgated by the GPT Applicant and its supporters, many of whom are paid for their voices. I was most recently reminded of this effort by seeing yet another slick, primetime TV advertising feature sponsored by the so-called 'Alliance for Northwest Jobs & Exports', claiming GPT has far wider support than seems credible. Their catch-phrase is BUILD TERMINALS HERE. BUILD JOBS HERE. This intensive campaign demonstrates an apparent dearth of business integrity, with self-serving monied interests trying to drown out legitimate public concerns by trivializing them and demeaning the credibility of GPT skeptics and opponents alike.

In a process that already seems inherently rigged to find a way to say 'yes' to any and all proposals submitted, this Applicant is engaging in a campaign of misleading statements, testimonials and indirect lobbying of the very Whatcom County, Washington State and US Government officials, who themselves are being involuntarily sequestered and/or compelled to remain impartially uninformed in the EIS Scoping and evaluation exercise.

This kind of shameless, self-serving charade -while likely not strictly illegal- simply adds to what is already widely perceived as an unfair process that will decidedly impact the future of our community, region, nation and globe. SSA-Marine and its backers seem to embody that strained concept that 'corporations are people and money is speech', and its corollary, wealth wins. Reducing this important issue to a 'pants-on-fire' political contest does not serve the overall interests of the public, which expects a fair, impartial and fact-based process likely to result in as unbiased result as possible.

The Applicant has had its opportunity to spell out its plans, with emphasis on claimed benefits, of course. Now, the agencies need most to hear the other side of the debate, the concerns, fears, doubts about potentially harmful impacts, including an assessment of all associated costs, and what's missing that needs to be known. Fortunately, the agencies have heard enough already to conclude that a much wider scope was needed than originally anticipated, as well as more opportunities for public comment. And, both of those determinations were distinctly opposed by the Applicant, who continues to stonewall the questions it doesn't want asked and disingenuously presumes no harms can come from GPT being built and operated. Is that the profile of a corporate entity we can trust to operate a major new terminal that will necessarily attract hundreds of coal trains and ultra-large vessels to our community? Or is it a manifestation of corporate interests without the kind of business integrity that inspires respect?

There have already been repeated requests from serious-minded people for broadening the EIS process even further for GPT, and considering it a part of an entire cluster of similar proposals - a so-called 'programmatic EIS' process. That concept also seems to reflect the plainly plural meanings of the phrase BUILD TERMINALS HERE. BUILD JOBS HERE. doesn't it?
So, I also request this all-inclusive programmatic EIS idea be taken, and very seriously followed by the MAP Team, even though one USACE official has already stated that might be 'unprecedented'.
The point is, GPT, itself, is unprecedented, despite the Applicant's self-serving claims to the contrary. And, sometimes, precedents do need to be carefully set. In our unique system of government, we, the citizens, get to have early and often input into exactly that precedent-setting possibility.

Since this GPT project will impact much more than just some corporate bottom line, it should be subjected to the most thorough scoping and evaluation possible. If that is accomplished -with or without precedent- I am confident the resulting recommendations will likely be the correct ones, since citizen concerns would be heard, considered and and fairly factored into the final decisions made.

Friday, November 30, 2012

Coal: EIS Scoping Comment No. 29

Diminution in value of my home & other properties
Diminution in value is a legal term of art used when calculating damages in a legal dispute, and describes a measure of value lost due to a circumstance or set of circumstances that caused the loss. 
I am concerned that building GPT and attracting 18 additional coal trains per day will devalue my home, as well as the properties owned by many citizens, especially those near the BNSF railway through Bellingham.

I request that a baseline estimation of home, rental multi-family structures, commercial interests and industrial operations be officially documented by the Whatcom County Assessor, effective now, showing the aggregate Real Property Value of all properties in Bellingham and Whatcom County, with special emphasis on those property parcels falling -all or partially- within 600 to 1000 feet of the BNSF mainline route to and from the proposed Cherry Point Terminal. Since RCW 84.40.045 requires this information to be updated periodically, this calculation ought to be fairly simple and readily available.

The purpose of this baseline is for comparison with similar determinations to be made in the future, should GPT be permitted, built and operated as currently anticipated by the Applicant.

It seems common to believe proximity to a busy rail freight route tends to reduce property values, especially residential and commercial parcels. At least one professional report has been prepared recently that addresses this problem directly. This can be found at this URL:

This report considered the following factors, which are considered as harmful impacts and/or nuisances:

Access and Vehicular Traffic; Life Safety Issues; Vibration; Horn Noise; Pollution; Stigma and Perception; Property Types, Variables and Comments, and came to some general Conclusions:
".... the closer the distance of the property to the rail line or crossing, the greater the influence. Because of this, in general, the upper end of the range of diminution in value concluded would be expected to strongly correlate with properties located closest to the rail line or crossing. At the opposite end of the spectrum, although property with the least net total intensity of adverse influence might be expected to experience a diminution in value of less than five percent, such minimal impacts are generally considered so slight as to be effectively immeasurable; therefore, five percent has been used at the lower end of the range." 
• "Property located north of Everett with 18 new train trips daily: the applicable range of diminution in value for single family residences, the property type expected to suffer the most severe impacts, has been concluded to range from five to twenty percent of market value. Multi-family properties as a whole, are considered to be less intensely impacted for reasons discussed in this report and would be expected to suffer a loss in market value ranging from five to fifteen percent of market value. ....Commercial properties would experience loss in market value in the approximate five to ten percent range.....Industrial properties, considered the least impacted of the property types overall, would be expected to suffer a five to eight percent range of loss in market value. 
Although this report is not intended to be used to provide an aggregate loss in value for property that would be affected by the proposed increase in coal train freight rail traffic, it is felt that the total loss in value due to such influence would be substantial in terms of property market value and real estate tax revenues to taxing districts." 
• "The proprietary database provided and used in this assignment indicates a total of 21,548 tax parcels for properties identified as located within 600 feet of the BNSF main line railroad tracks in the subject area of interest, with a total aggregated assessed value of $26,556,663,168. If one were to assume these properties would suffer a loss in assessed value of one percent, the loss would be equal to approximately $265 million, which applied at a one percent millage rate is equivalent to an approximate $2,655,000 in annual tax revenue loss. In my opinion, the effects and impacts of the additional freight rail traffic not only affect the properties within 600 feet of the main line, but also potentially affect property beyond this identified zone. At the very least, this information indicates that the aggregate losses to market value and tax revenues could be quite substantial. 
I request the MAP Team take these expected impacts into careful consideration in the EIS Scoping process, because they represent very substantial tangible harm, especially to those living, working or owning property near the BNSF main rail line.

Thursday, November 29, 2012

Coal: EIS Scoping Comment No. 28

Does GPT mean Gambling Public Trust?

I am concerned that the GPT proposal represents nothing more than a deliberate depletion of publicly owned coal for speculative private gain, at needless sacrifice of the human and natural environment.
When any plan seems too good to be true, often, it likely is!

Since our country has an announced goal of energy independence, why allow the export of non-renewable resources like Powder River Basin Coal?
Why not leave the coal unneeded for current domestic purposes in the ground for future emergencies, similar to we do with the strategic petroleum reserve?
Temporary over-supply of coal, petroleum & oil, natural gas, bio-fuels from subsidized corn, and the like, has historically happened over time, so why not plan for it?

Shouldn't our national energy policy be determined by the Federal Administration & Congress, not the wildly fluctuating global market involving 3rd-world countries?
A good practice would be to pace ourselves, emphasize energy efficiency, conservation, and development of alternate, renewable sources?

And, why would the US wish to weaken its future strength by quickly selling off its natural assets as non-value added commodities to its main competitor?
Such unprecedented shortsightedness needs to be strongly questioned, both from a public policy point of view and as a risky investment that depends on windfall profits over a few years.

Loss of coal resources, instability of promised tax revenues and jobs, impacts to public health & safety and degradation of the environment, all seem to exact a heavy price to pay for a private equity gamble masquerading as beneficial and sustainable, economic growth for the public.

While the Applicant's [SSA] other corporate collaborators are not risking significant capital themselves, SSA -backed by Goldman Sachs- really is taking a big risk. 
Peabody Coal will get paid by its Asian customers before it ships one lump of coal; 
BNSF will be paid for what it hauls on its tracks for Peabody; 
ultra-large Bulk Carriers will be paid before they take on any coal cargo for Peabody. 
But, GPT is the one critical facility for which substantial investment is essential, because without it being permitted, built and operated, none of the other transactions mentioned would become enabled, nor would SSA earn any revenues from its Cherry Point proposal.  

I therefore request the MAP Team press this Applicant -SSA-Marine- for its pro forma expectations for payback to confirm or deny that GPT is truly a project meant to sustain itself for the long life expectancy it claims. 
While corporations and investors are free to take substantial monetary risks to earn higher returns, it is not healthy to collateralize those risks by foisting a deception upon local governments, citizens and the impacted natural environment. 
Solid, sustainable business is not usually predicated upon quicksand-like foundations, as the GPT proposal appears to be.

Wednesday, November 28, 2012

Coal: EIS Scoping Comment No. 27

San Juan Islands National Conservation Area
There is much current interest in the idea of designating a San Juan Islands National Conservation Area, because the area is so spectacularly beautiful. This sentiment is not new; it has been widely shared by many for a long time, since all who visit this unique place enjoy the experience and want to preserve it for future generations.
I'm concerned that the very large Bulk Carrier Vessels that GPT will attract, will degrade this area and possibly even ruin it for fishing, boating and general enjoyment by the tens of thousands of people who live there or visit each year. It is difficult to conceive of any mitigation capable of undoing the irreparable harm that a spill, collision or sinking could cause, not to mention the enormous threats to small craft, ferries and recreational uses these huge vessels would certainly cause.
I request that the MAP Team strongly consider what preventative measures could possibly be put into place so as to minimize this threat, including all necessary costs and mandated protocols to be implemented by the Applicant.

Tuesday, November 27, 2012

Coal: EIS Scoping Comment No. 26

Tugs, Pilots, Spill Response & Rescue Vessels

If GPT is ever built, nearly 500 ultra large Bulk Carriers may be attracted to Cherry Point each year. 
Each of these Capesize [up to 70-foot draft] and Panamax [up to 40-foot draft] vessels will require the likely assistance of 2 to 4 powerful tugboats, plus registered pilots and, hopefully, mandatory spill response and rescue work boats.
While necessary for safety and ecological prudence, these additional vessels represent additional marine traffic and potential harms, making it necessary to fully consider them in any comprehensive EIS.

Here are some specific questions for the MAP Team's consideration:
For Tugs -
• What criteria will be used to determine the size, horsepower power ratings, crew size and number of tugs required for each ultra-large vessel as it arrives and departs? 
• At what point/location will these tugs meet these incoming vessels? At what point/location will tug escort be ended for outgoing vessels?
• Where will these tugs be based? Is there a plan for tugs to be based at Cherry Point?
• What proportion of tugs will qualify as ocean-going? 
• Will all tugs be equipped with water monitors, in the event that water-borne firefighting is necessary?
• What grade of diesel fuel will the tugs use? What are the anticipated air emissions (per hour)? Where will fueling be done?
• Some larger tugs are rated at 25,000 to 30,000 Horsepower, or 5 times that of larger diesel locomotives. Will these be necessary to maneuver ultra-large vessels? When, and under what weather and marine conditions?

For Pilot Boats -
• At what point/location will these Pilot Boats meet these incoming vessels? At what point/location will the Pilot escort be ended for outgoing vessels?
• Will the Pilot have discretion over vessel movement decisions -including tugs- under all sea-state and weather conditions? Over excessive vessel traffic in close or restricted waters? 

Spill Response Work Boats -
• What plans for Spill Response apply to to GPT? 
• Specify what type of specialty work boats will be required to be immediately available, should a fuel or other spill be encountered. What equipment is to be carried? What crew size and training?
• Who provides these work boats? Who pays for them? Where will they be based?

Rescue Vessels -
• What specific plans does GPT have to provide rescue services on demand? Who pays for this?
Where will these vessels be based? What role is anticipated for the US Coast Guard?

It is essential for answers to these questions be developed and made available to the public before any approvals are granted to GPT. 
Each of these support craft carries its own impacts on vessel traffic, nearshore water disturbance, and potential impacts on the marine ecology, most particularly the tugs with their powerful engines and thrusters capable of moving 250,000 dwt Bulk Carrier Vessels.

Monday, November 26, 2012

Coal: EIS Scoping Comment No. 25

Non-reimbursed Government Expenses 

Governments at all levels are continuing to incur significant expenses related to permitting and administering the GPT proposed project, that are not paid by the Applicant. 

For instance, Whatcom County has spent thousands of dollars to date on activity even before permitting officially began, yet charged the Applicant only the $2500 fee generally applicable to 'normal' permit applications. 
For an exceptionally complicated project containing major wider implications and potential harms, the standard fee is woefully inadequate and essentially represents a public gift to a private entity. 
This practice is grossly unfair to taxpayers and needs to be mitigated.
Although law does require the Applicant to pay for EIS costs, this does not necessarily include all the considerable staff time from each of the public agencies involved, not to speak of the untold hours of voluntary, uncompensated, citizen time in even expressing legitimate concerns for possible inclusion in the EIS.

I request that Whatcom County immediately undertake to assess the costs of these uncompensated services and make this information available to County officials and the public at large, as a first step in redressing this obvious inequity. 
Without such information, neither County officials nor citizens will even know the extent of any financial burden being silently foisted upon the public treasury. 
Such abuse must be identified and curtailed, in this case, by County action.

If these types of subsidies are routinely granted to Applicants during the initial permitting process, just imagine what other, much greater financial demands might become expected and imposed upon local governments should the project be approved! 
The Applicant's claims of additional jobs and tax revenues could easily be dwarfed by the costs of required new public infrastructure, such as grade-separated crossings all along the BNSF railway that bisects multiple municipalities and greatly increases safety and convenience problems with citizens and businesses alike. 

Please consider these uncompensated costs -both current and potential future- as important factors in fairly weighing costs versus benefits.

Tuesday, November 20, 2012

Politics & Political 'Science'

Aristotle considered politics -and ethics for that matter- as a 'practical' science, not an exact one in the manner of mathematics, etc.
Pretty smart, that guy!

With the Rombot and Ryanoid soundly defeated, much to their surprise however much deserved, our ship of State continues its stable, if not always exciting course. 
Of course, the political gamesmanship doesn't all go away, because many important decisions must still be made, some of longstanding ripeness and others predictably unpredictable. 
No, the waters being traveled are calm only in their relativity, with squalls, shoals, other ships of State, and all sorts of perilous situations that demand wisdom, courage, cooperation, leadership, as well as Divine Providence.
These are not traits for those specializing in gaffe ability, flip-floppiness, fuzzy math, unbalanced pretense, or habitual mendacity - not to mention Romnesia or Ryanopia.

The Party of 'NO' -what now tries to pass as Republican- has at least for the present acknowledged that its has some very serious ailments, which if not addressed immediately, could metastasize into something lasting, if not fatal.
For their sake, and every one's, I hope they find a cure that allows them to be more inclusive, more accepting, less bellicose and more honest. 
The R's aren't all bad people; they have just allowed a few ideologues to usurp their party, whether self-serving established elites, mean-spirited tyrants, parsimonious misers, posturing politicos, or just non-thinking followers of spin-mongers.
But, that's the nature of the reality that must be faced.
Good luck with that. 

Thursday, November 1, 2012

Coal: EIS Scoping Comment No.24

Proposed BNSF Bellingham Siding & Idling Track

There have been reliable reports that BNSF is actively proceeding with plans to build a new siding -perhaps 1.5 miles long- within Bellingham City Limits, ostensibly to help accommodate anticipated additional Coal Train traffic for the proposed GPT export facility. 

Yet, nowhere within the Application submitted by GPT & BNSF is this particular plan even mentioned, even though it would create additional severe impacts to City facilities and infrastructure. 

I request the MAP Team investigate this report to determine its accuracy. If BNSF is planning such an idea within the anticipated GPT EIS time frame, it most definitely should be included as part of the GPT EIS Scope and fully evaluated for its additional impacts, possible mitigation and all related costs.

Since GPT and BNSF -as inseparable Applicants- have consistently tried to limit the EIS Scope to only those footprints specific for the Terminal & Custer Spur expansion, the omission of this new, long and disruptive Bellingham Siding has the appearance of a deliberate attempt to evade comprehensive public scrutiny by the evaluation team.

If this new siding and idling track is built, it would permanently block Boulevard Park to vehicles & parking, affect Waterfront Businesses -both existing & planned- and increase train diesel exhaust in a populated urban area. 
It would also impose a significant, unfair financial burden on the City and its taxpayers and citizens if public health, safety and welfare problems are to be even partially rectified.

All of these impacts are simply unacceptable to me and to our community, even if some form of limited mitigation funding were offered.
I suggest a No Action Alternative may be the only reasonable solution to this situation.

Wednesday, October 31, 2012

Coal: EIS Scoping Comments No. 21, 22, 23

“...all types of benefits and costs, both market and non-market, should be considered. To the extent that environmental and other non-market benefits and costs can be quantified, they shall be given the same weight as quantifiable market benefits and costs.” - from USACE guidelines
EIS Comments No. 21 & 22 were submitted via the weblink provided by the MAP Team.

The text of No. 21 on Liability Responsibility also appears at the end of the 10/29 blog.

The text of No. 22 on Train Noise will be viewable within the next week on the MAP weblink.
In the meantime, here are excerpts from a previous blog on this subject:
At a speed of 10 MPH, it takes about 8 minutes for a 1.35 mile-long train to pass any set point.
At 20 MPH, about 4 minutes
At 30 MPH, about 3 minutes
At 40 MPH, about 2 minutes

Most trains passing through Bellingham don't exceed about 30 MPH, and sometimes less.
BNSF tracks closely follow Bellingham's shoreline, which extends about 10 miles from City Limits, North & South.

So, the leading locomotive engine [with Horn] might require about 20 minutes to traverse the entire City, leaving about 8 minutes for the rest of the train to pass, with its track noise.
Of course, the Horn gets blown before reaching the City and can be heard after it leaves the City.

But, if we say each additional train will be heard by City residents for 20 minutes, then nine additional trains will be heard for 180 additional minutes [3 hours] per day. [18 trains = 6 hours]
Remember, this is in addition to the number of trains -about 9- that are already traversing the City. Adding existing and additional trains may total [well] over 4 hours per day of Horn noise, allowing that some existing trains -think AMTRAK- are much shorter than 1.35 miles.

The point is, what may be tolerable at current levels may become much less tolerable at elevated levels, particularly at night.
If I can hear the train Horns from 2+ miles away, I'm pretty sure those living closer to the BNSF tracks will hear them too, and at higher decibels. 
And NOISE is only one part of the potential impacts of additional trains carrying heavy loads.-----------------------------------
More notable published information appears at these URLs:

• Whatcom Watch Oct/Nov 2012 Issue contains this useful 20-page insert on the Cherry Point Aquatic Reserve.

• Today's Cascade Weekly carries an article by Bob Simmons on the Oct 27 Scoping Meeting.

• Sightline carried this article on air pollution from vessels in Puget Sound.
Here is Comment No. 23:

Misuse of U.S. Coal Resources 
I request the Scoping Team to perform a study on the underlying economics of the GPT proposal that weighs its claimed benefits against factors that the proponent(s) wishes to ignore or simply externalize. Some of these considerations involve larger matters of national policy and security that ought not be lumped together and treated as a simple market transaction.
Depletion of any domestic fossil fuel resources by export to foreign countries is wasteful, costly and short-sighted. The Powder River Basin [PRB] sub-bituminous coal targeted for export through the proposed GPT facility actually belongs to the American people, who if given the chance, would not willingly agree to selling it, especially to America's largest competitor, China. 
This particular source of coal is often called 'steam coal' because that is its primary use; to fuel power plants producing electricity. The quantity of coal that GPT wishes to export would be sufficient to fuel eight (8) 1000 Megawatt power plants. Ironically, the use of PRB coal was greatly stimulated by concerns that the extensive use of harder grades of coal was excessively polluting our atmosphere with sulfur and nitrogen oxides, thus requiring expensive retrofitting of power plants to reduce this pollution. 
Many power companies have simply sought to avoid these retrofit costs by switching to PRB coal, which burns cooler and cleaner, costs less and is readily mined in quantity by highly automated surface methods, that so far have been less controversial than traditional techniques. Those decisions were motivated primarily by domestic economic factors existent at the time. The result has been a dramatic increase in PRB coal usage at the expense of traditional sources. Now, with the advent of plentiful natural gas, many of the same power companies have opted to use that fuel instead of coal, in turn creating another market dislocation that mining companies are desperately seeking to rectify by indiscriminately promoting new markets in Asia and elsewhere. That alone, is the motivation for proposals like the GPT Terminal.
But, the truer long term interests of America do not support exporting strategic resources like coal because if we are to become energy independent, we need to conserve our natural resources that are not readily renewable. Even though the US needs to reduce its use of coal because of its polluting nature, it is still an important resource that will be needed centuries from now, when new technologies are available to utilize it more safely. On some future day we could easily regret exporting this energy resource for short term gains for a few opportunists.
The GPT proposal would essentially subsidize US-owned resources for foreign interests, because leasing charges for mining companies amount to less than $1 per ton, a fraction of the actual value. While this kind of subsidy might be justified for domestic purposes, allowing it for coal exports is a really bad idea! It would be better to simply sequester the coal in-place as a strategic reserve for future emergency or use as a readily available petrochemical feedstock.

Tuesday, October 30, 2012

Coal: EIS Scoping Comment No. 20

Loss of Use of Parks & Trails

Public parks are widely enjoyed in Bellingham, and millions of dollars in additional, dedicated funding has been voluntarily supported by citizens for many years.
Visitors, including tourists also are drawn to these amenities that are recognized as world class.

Unfortunately, many of these facilities happen to be on the shoreline and are accessible only by crossing the BNSF tracks, the prime example of which is Boulevard Park, which is very frequently visited by families with small children and others who walk the Taylor Street Dock over water route from Fairhaven to Bellingham.

18 additional coal trains per day will significantly render these popular public places less usable with increased safety hazards at crossings, and considerably more noise from coal trains.
It is difficult to conceive of mitigation capable of negating all of these objectionable impacts unless a no action alternative is adopted.

Failing that, a grade-separated crossing at the north end of Boulevard Park, adequate to accommodate walkers, joggers, baby strollers, bicycles and other pedestrian traffic, needs to be constructed -prior to increasing rail traffic- at BNSF expense.
That would partially eliminate some danger and the noise of train horns at one crossing.
Similarly, the single vehicular access to Boulevard Park will need mitigation to allow deliveries, repairs, preparation for concerts and events and continuation of existing parking.

Another grade separated crossing will also be needed to allow Wharf Street traffic -both vehicular and pedestrian- to safely cross the BNSF tracks to access the waterfront south of Cornwall Street.
This would serve several purposes;
(1) mitigation of safety & noise impacts, 
(2) important access for activities related to the Waterfront Redevelopment undertaking, 
(3) access to the water for small craft, 
(4) access to the proposed future extension of the Taylor Street Dock over water walkway north from Boulevard Park to the south of Cornwall landing. 
A significant part of these costs should be borne by BNSF as well, since the City's planning process has focused on this future development area for many years.

There are several other Parks destinations that will also need careful attention, evaluation and funding for mitigation should BNSF increase rail traffic as has been proposed.
These include:
(a) Clayton Beach - a popular recreation area accessible via trail from a specially built parking lot on Chuckanut Drive.
(b) access road to Wildcat Cove boat launch area in north Larrabee State Park.
(c) Teddy Bear Cove accessible by steep trail crossing BNSF tracks.
(d) several informal track crossings between Chuckanut Point and the Post Point Wastewater Treatment Plant.
(e) Port of Bellingham's Marine Park, another popular place that has become the finish line for the annual Ski to Sea race. 
== don't forget the Ferry Terminal, southern terminus of the Alaska State Ferry ===
(f) the public boat launch at the mouth of Padden Creek.
(g) proposed trail route through the waterfront redevelopment area accessed by Central Avenue from Roeder Avenue. [must cross BNSF tracks to reach Roeder]
(h) access to Bellwether Way business complex and Squalicum Marina & yacht basin via "C" Street or "F" Street to Roeder crosses BNSF tracks.

The MAP Team needs to take into account the well established long-term use of these shoreline access points and their importance to Bellingham.

Also, since the Port of Bellingham's purchase of the former G-P industrial site, both Port & City have invested or committed millions in public funding toward waterfront cleanup, rezoning for mixed use and a likely decades-long redevelopment to create suitable, desirable sites for business, jobs, residences and recreation for future citizens on its waterfront.

In sum, the waterfront is intended to become -again- Bellingham's front door and everyone's neighborhood.
When appraising the certain harm that increased BNSF coal trains bring to these goals, please remember they reflect the wishes of thousands of citizens over many years, and need to be fully respected as the highest priority for achieving the net public good.
Note: The title declares this to be Comment No 20, but prior to posting this I submitted 2 additional comments, using the online form at this URL.
No. 21 was about who has responsibility for liability at each stage of the coal shipping process, as I stated at the Scoping Meeting at Squalicum HS last Saturday.
No. 22 was about train noise.
Stay tuned.....