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

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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.

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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.

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.

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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.....

Coal: The Public Weighs In

Last Saturday was one of those days that I felt particularly proud to be a member of this community.
My wife and I went to Squalicum High School about 10AM to attend the GPT EIS Scoping session, held in response to public demand by the Multi-Agency Project Team- US Army Corps of Engineers, WA Dept of Ecology & Whatcom County Planning.

To our surprise and delight, we found hundreds of fellow citizens already there, standing in the light rain, in cheerful spirits and primed to voice their concerns as well as listen to others.
Some had been there since 6AM, to make sure many speaking opportunities were available to those who were not paid advocates for GPT.

At about 1PM, we left, after hearing dozens of inspired and heartfelt concerns expressed -and recorded by the MAP Team stenographer- by a crowd that was almost unanimously against one of the most controversial ideas -GPT- that this area has seen in recent years.
By that time, only one speaker had voiced support for GPT, and even that seemed pretty thin and weak.
From talking with others, the larger room -the gym- experienced the same overwhelming sentiment of concerns for the GPT proposal proceeding.
That impression could not have been lost on the visible GPT proponents, who despite spending big money on a multi-media advertising campaign, were badly outnumbered -and outspoken- at this event.

It will be interesting to see what impact this first EIS Scoping session will have on the EIS evaluation itself, since many of the concerns expressed may not have had full representation in the bureaucratic format used by the evaluating agencies.
Time will tell, but I think the cause of those with concerns was helped by this meeting.
Now, it is necessary to continue submitting our concerns and to convince others to attend the remaining 6 EIS Scoping sessions planned for other venues.
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As before, there were some good articles published -both prior to and after the meeting:

This Floyd Mckay Crosscut article is particularly relevant, since it reaches farther into the zone of GPT influence than most others to date.

Three articles on Get Whatcom Planning:
Jean Melious posted these pieces about GPT recently, one before and one after the EIS Scoping meeting.

This morning, Dave Stalheim followed with this writing questioning the financial benefits claimed by GPT.

The Bellingham Herald published this account of the EIS Scoping session by John Stark.

Whatcom Watch printed 2 articles by Terry Wechsler on how to submit a scoping comment for the GPT EIS, and the history and implications of Cherry Point.
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This is the concern I expressed in the Auditorium as speaker No 33 -[although not entirely within the 2 minutes allocated]:

(EIS Scoping Comment No. 21)
GPT is a 'Field of Dreams'.
If you build it, 'they' will come....
But, who are 'they'?
• Almost 3000 1.5-mile long unit trains of coal will come, plus return trips - each year
• Almost 500 huge bulk carriers, burning fuel much dirtier than coal, will come, plus return trips - each year
Without GPT, there would be no reason for this level of harmful traffic coming into Whatcom County.
This 'Field of Dreams' could easily become a 'Port of Nightmares'!

Who will be responsible for the enormous potential liability involving this traffic?
The owners of the coal and those deriving profits from carrying and handling it need to be the responsible parties!
Not the public!

To protect the public interests, the State of Washington needs to require a very substantial guaranty bond to be timely used to clean up and mitigate any spills, accidents, sinkings, collisions and other harms resulting from the care, custody and control, especially of coal for export.
The amount may need to be $100 million US dollars, to be automatically replenished to that level during the expected life of GPT and its successors and assigns, and increased as necessary in the event of a catastrophic event similar to the Exxon Valdez grounding in Alaska.

This fund -from insurance, bonds, or otherwise- needs to be established prior to any approval being granted to GPT for construction of any part of the terminal.
Additionally, legal mechanisms need to be fully in place to effectively appropriate and expend these funds by a public agency in the event they are needed for mitigation, cleanup or rescue activities.
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GPT: EIS Scoping Comment No. 19

Tribal Concerns

Today's New York Times ran an article on this issue which captures the concerns expressed by the Lummi Nation and other Northwest tribes, who are voicing strong oppositions to the GPT proposal to begin shipping up to 54 million metric tons of coal from Wyoming to Asian markets through a huge, new bulk terminal at Cherry Point, part of the ancestral lands of the Lummi's.

Several factors motivate this opportunistic -and potentially very harmful- venture, not the least of which includes the falling US coal market, as described in this article.
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GPT's Application devotes several paragraphs to acknowledging aspects on the subject of tribal concerns, albeit somewhat clinically. 
Chapter 5, Affected Environment / Environmental Consequences is where these comments are located, and paraphrased within the following subsections:

5.1 ENVIRONMENTAL RESOURCES AND PROJECT EFFECTS - describes the existing natural and human environment in and around the proposed project area and describes some potential effects of the proposed Terminal on these resources. 


5.3 Marine Resources - includes information on forage fish, an important prey fish for a variety of larger marine fish and marine mammals. Forage fish are known to spawn on intertidal beaches at Cherry Point; however, only herring are known to spawn near the project area.

The Applicant acknowledges that Cherry Point herring are known to spawn in the project vicinity and have shown a large decline in abundance since 1973. Studies have been conducted to identify the cause(s) of their decline, with 'general agreement' that the decline was probably initiated by a periodic, recurring shift in climate that occurred in 1977, plus other contributing factors like physical stressors, such as temperature and salinity; biological stressors, such as lack of suitable food supply, competition, larval abnormalities, reduction in size at maturity, parasites, disease, and predation; and anthropogenic stressors, including fisheries harvest, habitat modification, vessel traffic, noise, contaminants, and ship ballast. Predation by species of birds, fish, marine mammals, and benthic invertebrates is another potential explanation for the decline. 

Then this; A more detailed analysis of the effects of the proposed project on Cherry Point herring will be included as an appendix to the Biological Evaluation.

Does that afterthought sound like 'paralysis by analysis' that is relegated to an after-the-fact footnote? 
Is that a substitute for facing the likelihood that building and operating GPT will lead to further declines and possibly extinction of the herring?

These following subsections don't give much comfort that GPT will do anything to help sustain the herring and other species in that food chain: [read them if you care

5.3.2 Effects of Construction on Marine Resources

5.3.3 Effects of Operation on Marine Resources

5.3.4 Proposed Design Features Intended to Reduce Impacts

5.5 Archaeological, Cultural, and Historic Resources - background research confirmed that the project area lies within lands and waters once occupied by several Puget Sound Tribes, whose descendants are represented by federally recognized Indian Tribes including the Lummi Nation and Nooksack Tribe, meaning a high level of archaeological sensitivity is assigned. [whatever that means]

Then, this legalistic gibberish; Section 106 of the NHPA, as amended, requires federal agencies to take into account the effects of an undertaking on historic properties, defined as cultural resources that are listed in, or eligible for listing in, the NRHP. Site 45WH1 is an archaeological site that has significance both as an archaeological resource, and as a potential Traditional Cultural Property.

Then, under Section 5.10 - ENVIRONMENTAL JUSTICE

5.10.1.4 Whatcom County Tribal Populations 

Tribal populations specifically located within Whatcom County warrant further consideration given their proximity to the project area and specific cultural and economic relevance of the Cherry Point area to both tribes. Comment letters presented within the 1997 Gateway Pacific Terminal Final EIS (Whatcom County 1997) state that the project area is located within the historic site of the Lummi Nation called Xwe’ Chiexen (Cherry Point), and several registered and unregistered areas of cultural significance exist within the project area. In addition, the Treaty of Point Elliott of 1855 provides the Lummi with primary fishing rights for the waters surrounding Xwe’ Chiexen. The Nooksack are also signatories under this treaty and have stated that they use the project area for economic (salmon) and spiritual/cultural uses (including crabbing, and clam digging).

Tribal Use of Coastal Resources
The Lummi, located directly south of the project area, have always been strongly associated with the ocean and have traditionally relied on seafood as a major component of their diet. The Lummi Nation is reportedly the largest fishing tribe in Puget Sound. However, declines in the regional salmon fishery have dramatically altered the tribal dependence on salmon fishing as an income generating activity since the mid 1980s. According to the Lummi Natural Resources Council, the declining fishery was specifically identified as a factor for this difference.
Yet, additional information would be required to establish the Lummi Nation as an Environmental Justice population based on income. 

Potential environmental justice effects include potential economic, environmental, and social impacts to the Lummi and Nooksack tribal members in particular, stemming directly or indirectly from construction and operation of the project.

Both the Lummi Nation and the Nooksack Tribe have requested more complete studies be commissioned in advance of any project approvals to understand more fully the associated risks and potential impacts to the marine environment and tribal fishing communities.

Mitigation measures in the 1997 Gateway Pacific Terminal Final EIS remain relevant in the absence of new data on the current state of the fishing industry and the Tribes dependence on it. 
Continued tribal consultation with the Lummi and Nooksack, as well as other Tribes with treaty rights near the project area (potentially the Suquamish, Swinomish, and Tulalip Tribes) should be important components of any impact-reduction strategy.

Finally, this; 5.10.3 Proposed Design Features Intended to Reduce Impacts

The current Environmental Justice status of Tribal populations based on income remains to be determined. Additional information on these populations, when available, will require review of potentially significant impacts and impact-reduction strategies with respect to qualifying populations.

Much of the bloviation cited above is meaningless boilerplate claptrap, intended to obfuscate the reality of what will plainly happen if GPT is built.
 It should largely discounted as obligatory lip service to principles that deserve to be treated honestly, completely and timely. Instead, they are temporizing, disingenuous and actually insulting to those with a care for sustainability.
This part of the Application needs to be given at least as much weight as any other part in a fair evaluation, and GPT required to complete all the unfinished studies alluded to in passing.
The MAP Team needs to level this playing field and not allow this latest attack on what remains of Lummi sovereignty to be destroyed!
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Is there any question that the Lummi Nation and their tribal allies have a legitimate beef with GPT?
Why would they want any part of the snake oil that SSA-Marine is trying to sell them?
Building GPT would effectively end the Lummi's fishing rights, which already have been seriously diminished -by degrees- for several generations.
Now, with this latest attempt to effectively destroy any vestige of sustaining the 1855 Point Elliot Treaty, what choice do the Lummis have but to challenge GPT with every means at their command.
After all, no mitigation is possible for inflicting irreplaceable harm on their fishing rights, cultural heritage, and traditional sacred lands whichremins their home and economic base.

Among the many reasons for performing the most comprehensive EIS evaluation possible, is to take a firm stand against crass, powerful financial interests like GPT and its backers and preserve what we can of the Lummi way of life.
The Lummi serve us as guardians of nature, which they clearly understand from history.
We need to thank them for that, and support them as we can to restore the herring by avoiding even more harmful effects from the traffic, pollution and other impacts that GPT will certainly bring.

Here is a link to the Lummi strategy and goals, which need to be incorporated as strong concerns:

'First, to defeat the proposed SSA project. Second, to acquire Cherry Point, have it placed in Trust status."

GPT: EIS Scoping Comment No. 18

GPT: The Liability Labyrinth Linchpin

The GPT Application is notable for what it asserts regarding SSA-Marine's own liability, but that is nothing compared to what is NOT said.
For example, the statement that GPT will not OWN any of the coal it plans to handle is technically true, but that begs the question; 'WHO DOES OWN THE COAL?'
Certainly someone does, and at every step of the inextricably connected chain of events, beginning with leasing public land and mining the coal, right through to delivering the coal to a customer who will then burn it, releasing millions of tons of pollutants into the same atmosphere that everyone on earth shares.

It seems reasonable to expect that the principle of 'they who benefit, ought to pay' should apply to this entire scenario.
But, the only way that goal can possibly be achieved is to use full-cost accounting methods to account for both ownership and liability for the coal at every step of the leasing/mining to combustion chain of custody. 
Only a comprehensive treatment - necessarily including all the factors that GPT and its partners wish to externalize - of costs & benefits can begin to even approximate the actual ratio of costs versus benefits to the public, which is critical to justify approval of this Application in any variant form.

The dirty little secret, which GPT would rather the EIS ignore, is this; Peabody Coal will own the coal until it's customers actually take possession of it. 
Even then, the chain of impacts will not be broken because burning the coal will create pollution that the global public will have to accept, without any recourse to effective mitigation in any form. 
If one understands and  believes that global warming and climate change are rapidly happening, largely due to humans burning fossil fuels, then there is clearly additional cause for concern as a result of GPT's proposal.
But, if one chooses to disbelieve these scientific facts, they are ignorantly -even willingly- dooming the rest of us to the same fate that they, and their descendants, will have no choice but to experience; the very harmful effects that will very certainly occur in the future.

So, by GPT asserting that it's parent -PIT- and it's parent -SSA-Marine, and it's parent -Carrix- and it's 49% owner -Goldman Sachs- and the other private owners of the other 51%- will have no ownership in the coal they will handle is technically 'true', but only according to the strained logic and  legal loopholes being so cleverly employed. 
One has to do work on 'peeling this onion' to even begin to understand what each corporate entity is deliberately shielding.
But, do these legal gimmicks actually excuse each of the parties from actually having at least a degree of liability?
Surely, some portion of the 54 million metric tons of coal that GPT believes it will only 'handle' for a fee, will escape -on GPT premises- as dust, spillage or sediment from storm water collection. 
Who will own that? 
What will be the mandatory method of mitigation? 
Of disposal?
Who will pay what, to whom, and when?

The same questions apply to the owner/seller, Peabody Coal and each of its chosen transporters.
What responsibility will be assigned to BNSF for its dust, spillage and loss of coal due to derailments? 
Will BNSF own this dust, spillage and loss? 
If so, to what limits and conditions?
What about the ancillary pollution from burning diesel fuel, specifically to transport the Peabody coal? 
Would there be any reason to burn this fuel -and create other impacts- were it not for its voluntary contractual responsibilities to Peabody?

Likewise, should not these same questions need to be asked about the various and sundry owners and operators of the huge bulk carriers that will take delivery of coal from GPT and transport it to Peabody's customers? 
Depending on the form of purchase, either Peabody or its customer could own the coal during its long ocean voyage to its ultimate destination.

􏰀 Cost, Insurance and Freight (CIF) – An international trade term of sale in which, for the quoted price, the seller/exporter/manufacturer clears the goods past the ship’s rail at the port of shipment (not destination). The seller is also responsible for paying for the costs associated with transport of the goods to the named port at destination. However, once the goods pass the ship’s rail at the port of shipment, the buyer assumes responsibility for risk of loss or damage as well as any additional transport costs. The seller is also responsible for procuring and paying for marine insurance in the buyer’s name for the shipment. The Cost and Freight term is used only for ocean or inland waterway transport. 

􏰀 Free On Board (FOB) – An international trade term of sale in which, for the quoted price, the seller/exporter/manufacturer clears the goods for export and is responsible for the costs and risks of delivering the goods past the ship’s rail at the named port of shipment. The Free On Board term is used only for ocean or inland waterway transport.

All the hazards and pollution involved in such vessel transport also need to be fully accounted for, with liability assigned and public surety guaranteed to pay for any accidents or cleanup costs incurred. 
The very vessels involved burn heavy residual petroleum oil as fuel, which contains significant concentrations of known toxic substances in the form of sulfur, nitrogen, arsenic, mercury and other heavy metals which are released into the air at volumes that almost rival that of actually burning their coal cargoes. 
At least one recent, reliable report indicates that air pollutants emitted from the residual fuel oil powering these large vessels adds another 80% on top of the total air pollutants [per ton] released from actually burning the coal! 
That heavy residual fuel oil would not be burned at all unless the vessels are first contracted to carry this coal, meaning that NOT shipping coal would eliminate this additional large source of air pollution, likely representing the only mitigation possible.

The whole point of this concern is that someone always owns the coal being shipped, and those parties need to bear full responsibility for any liabilities incurred throughout the entire continuum of the cradle-to-grave logistics train involved, of which GPT is the critically important link that actually enables it. 
Because GPT is the linchpin upon which this entire process depends, then surely any truly comprehensive EIS scope could not reasonably ignore the much wider, connected impacts as described above. 

If the MAP Team concludes a much wider scope than that desired by the Applicant [e.g. only the 350 acres at the GPT site] is more appropriate, the essential full-cost accounting approach will be much more sufficiently fulfilled. 
Should that result in an analysis and evaluation that recommends the GPT project should proceed, then so be it.
But, even in that case, each participating party needs to be apportioned it's fair share of responsibility and liability, and required to post adequate bonds or other appropriate insurance to cover its share of costs of mitigation for accidents, spills and impacts wherever they may occur. 

It would be unfair -to the point of being grossly irresponsible- if this essential financial determination and apportionment were not timely made, and in a form likely to be effective in both protecting the public and the ecological systems that humans rely upon for their sustained well being.

However, if the cost-benefit analysis shows public costs exceed the benefits, this Application should be summarily denied. 
In either case, it is requested that this assignment of responsibility during each step of the logistics train be undertaken simultaneously with the EIS evaluation, so that public interests are matched with both the evaluation process and its conclusion.

Finally, I believe that all federal agencies, including the U.S. Army Corps of Engineers (USACE), have an obligation to demonstrate that projects authorized or facilitated by that agency are justified on the basis of net public benefits. This net public benefits accounting framework is essential to sound decision making. As part of this, tracking externalized costs is a standard requirement for evaluating all public expenditures. Additionally, natural resource damage assessment (NRDA) procedures probably need to be applied.

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For comparison purposes, the 54 million metric tons of coal the GPT proposal wishes to handle would fuel eight [8] 1000 megawatt coal-fired power plants, or sixteen [16] times the case study shown below:

A Case Study: The Side Effects of a Coal Plant
A 500 megawatt coal plant produces 3.5 billion kilowatt-hours per year, enough to power a city of about 140,000 people. 
It burns 1,430,000 tons of coal, uses 2.2 billion gallons of water and 146,000 tons of limestone.
It also puts out, each year:

• • 10,000 tons of sulfur dioxide. Sulfur dioxide (SOx) is the main cause of acid rain, which damages forests, lakes and buildings.
  
• • 10,200 tons of nitrogen oxide. Nitrogen oxide (NOx) is a major cause of smog, and also a cause of acid rain.
  
• • 3.7 million tons of carbon dioxide. Carbon dioxide (CO2) is the main greenhouse gas, and is the leading cause of global warming. There are no regulations limiting carbon dioxide emissions in the U.S.
  
• • 500 tons of small particles. Small particulates are a health hazard, causing lung damage. Particulates smaller than 10 microns are not regulated, but may be soon.
  
• • 220 tons of hydrocarbons. Fossil fuels are made of hydrocarbons; when they don't burn completely, they are released into the air. They are a cause of smog.
  
• • 720 tons of carbon monoxide. Carbon monoxide (CO) is a poisonous gas and contributor to global warming.
  
• • 125,000 tons of ash and 193,000 tons of sludge from the smokestack scrubber. A scrubber uses powdered limestone and water to remove pollution from the plant's exhaust. Instead of going into the air, the pollution goes into a landfill or into products like concrete and drywall. This ash and sludge consists of coal ash, limestone, and many pollutants, such as toxic metals like lead and mercury.
  
• • 225 pounds of arsenic, 114 pounds of lead, 4 pounds of cadmium, and many other toxic heavy metals. Mercury emissions from coal plants are suspected of contaminating lakes and rivers in northern and northeast states and Canada. In Wisconsin alone, more than 200 lakes and rivers are contaminated with mercury. Health officials warn against eating fish caught in these waters, since mercury can cause birth defects, brain damage and other ailments. Acid rain also causes mercury poisoning by leaching mercury from rocks and making it available in a form that can be taken up by organisms.
  
• • Trace elements of uranium. All but 16 of the 92 naturally occurring elements have been detected in coal, mostly as trace elements below 0.1 percent (1,000 parts per million, or ppm). A study by DOE's Oak Ridge National Lab found that radioactive emissions from coal combustion are greater than those from nuclear power production.

The 2.2 billion gallons of water it uses for cooling is raised 16 degrees F on average before being discharged into a lake or river. By warming the water year-round it changes the habitat of that body of water.----------------------------

GPT: EIS Scoping Comment No. 17

Impacts on Property Values, Taxes & Levels of Service

As a property owner, taxpayer and user of public services, I am concerned about the possible adverse impacts on the three listed topics above from a dramatic increase in coal trains passing through Bellingham to service the proposed GPT facility.

I request that a comprehensive evaluation be conducted to determine to what level these three topics might be affected by an additional 18 coal trains per day.
The results of this evaluation need to be incorporated into an overall cost-benefit analysis for GPT.

The value of my home will likely be reduced for the reason that there are no municipalities similar to Bellingham that I know of which have had property values increase as a result of significantly greater freight train traffic, particularly 1.5 mile long, unit coal trains.
Real estate professionals know -and often say- that property values depend on three things; location, location and location.
Conversely, railroads have been often associated with generally depressing property values, especially once a town or City is well established.
In fact, the term 'shanty town' is used to describe some unfortunate communities that met this fate.

The taxes I pay to Whatcom County & Bellingham may need to be raised more than usual because of the need to raise funds to mitigate problems the added trains will likely bring; things like grade-separated crossings to maintain normal safety for citizens, noise barriers, pedestrian crossings and the like.

Levels of service for police, fire and EMS may be reduced because of blocked rail crossings, leaving these externalized costs to be borne by citizens and businesses, not GPT.
Maintaining adequate and customary levels of service will likely account for a significant proportion of otherwise necessary tax increases.
GPT related activities will add to this problem by requiring services not now needed, due to accidents, emergencies and general congestion directly connected with GPT operations.

The sum of all these impacts will end up being borne by taxpayers, unless substantial mitigation can be obtained from GPT investors and partners.
This amount needs to be determined during the EIS, so that any mitigation can be quantified, assessed and exacted from the Applicant.

GPT: EIS Scoping Comment No. 16

Climate Change: Who's Responsible?

The GPT Application Chapter 5.7 Air Quality - Section 5.7.2.3 is titled 'Energy and Climate Change'
It reads, in part;
The Council on Environmental Quality (CEQ) and Ecology have issued guidance on considering the effects of greenhouse gas emissions in the evaluation of proposed agency actions under NEPA and SEPA, respectively. These guidance documents advise agencies to identify and quantify meaningful greenhouse gas emissions directly associated with a proposed action. 
However, CEQ has acknowledged that the utility of analyzing greenhouse gas emissions in an environmental review under NEPA is limited because of the indeterminate linkage between specific environmental or climatological affects and a specific project or emission source. ....blah, blah, blah.....

Remember that underlined part, because it's the prelude to GPT's strategy to escape responsibility.
Section 5.7.2.3 continues, thus;

As a bulk products terminal, the Gateway Pacific Terminal would not be required to conduct greenhouse gas reporting under current local, state, or federal regulations. ....blah, blah, blah......

Then it goes on;
The Gateway Pacific Terminal would function as a transfer point in an international transportation system. 
Pacific International Terminals would not own, or process in any way, the commodities that would be received and dispatched by the Terminal. 
Likewise, the company would have no direct control over the source or destination of individual commodities, or the volumes of such commodities transferred from land-based transportation to oceangoing transportation. The volume, type, and mix of commodities transferred at the Terminal would be determined primarily by international market forces and the business interests of the Terminal’s customers. ...blah, blah, blah.....

What would GPT agree to be responsible for, one might ask;
Greenhouse gas emissions from the Terminal would include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) associated with such Terminal activities as loading and unloading, stockpile shaping, rail and marine traffic, heating, and construction. ...blah, blah, blah.....

OK, you get the idea, GPT is trying to avoid the obvious impacts of shipping 54 million metric tons of coal to Asia to fuel power plants. Nice work, if you can get it!
But, GPT would be glad to comply with all standards for the minuscule portion of greenhouse gases [ghg] that happen to escape from its 350 acres;
Measurements of each gas are converted to carbon dioxide equivalents (CO2e) using EPA-specified calculations. The emissions estimate will be prepared following final design and permitting, so that any final project changes are reflected in these estimates. 
The emissions estimate shall be performed consistent with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard, a set of standards developed on behalf of the World Resources Institute and the World Business Council for Sustainable Development. ...blah, blah, blah....

No one blames an entrepreneurial corporation -with deep-pocket, arm's length partners- to try and limit it's liabilities and maximize its profits, do they?
Before you answer that question, please understand what all that coal GPT wants to collect handling fee on will be used for in China or some other Asian country.
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Now, the point of this concern:

There exists near Macon, Georgia, a large power plant called Plant Scherer, which in 2006 was the largest single point-source for carbon dioxide emissions in the United States. 
It was also ranked the 20th in the world in terms of carbon dioxide emissions by the Center for Global Development on its list of global power plants in November 2007. 
It was the only power plant in the United States that was listed in the world's top 25 Carbon Dioxide producers.

The coal used at the Scherer plant comes from Wyoming's Powder River Basin, and is delivered by BNSF to the plant by in unit trains of up to 124 cars.

Plant Scherer burns nearly thirteen hundred coal trains a year -- two thousand miles of coal cars, twelve million tons of the bedrock of Wyoming. 

It unloads, on average, three and a half coal trains a day.

Plant Scherer produces a total of 3520 megawatts [MW] of electrical power, using four 880 MW units.

The 54 million metric tons of coal that GPT wants to ship to China would be enough to fuel 2.26 times the amount that Plant Scherer produces.

That is the equivalent of eight (8) new 1000 MW power plants.

What is wrong with this picture?

No one wants to accept responsibility for the new greenhouse gases [ghg's] that combustion of all this coal will produce, that's what!

These huge emissions need to be accounted for in the EIS, in terms of directly related impacts, as a large factor in a benefit versus cost analysis, and included in a comprehensive health effects evaluation that includes not only green house gases, but also particulates, like mercury, that have been proven to fall in the US.

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GPT: EIS Scoping Comment No. 15

Wasteful Water Use

The GPT Application -Section 5.13.1.2- contemplates the use of 5.33 Million gallons per day of PUD #1 water, primarily for coal dust suppression and reduction of spontaneous combustion risk.
However, there are likely better uses for this water, such as for agricultural use, in-stream flows, hydraulic well re-supply, etc.

This amount represents almost one-third of the approximately 17 million gallons a day of PUD supplies of industrial water to other industries located at Cherry Point; just over a third of its total water rights of 53 million gallons a day. 
The estimated water supply is anticipated as sufficient for all GPT terminal operations including dust suppression, plus fire suppression and safety.
GPT would make its own potable water by treatment of industrial water with a reverse-osmosis treatment system.

For comparison, this GPT water is equivalent to about one-half of the water used by the City of Bellingham per day to supply the needs of over 95,000 people.

It has been estimated that the water permits already issued in Whatcom County by DOE may amount to up to 2.5 times the water that is actually available.
In the interest of responsible water conservation -already a serious seasonal concern for the Nooksack River and its drainage- does this projected use make sense?

How much, if any, of this water will be reclaimed for re-use?
Will the storm water treatment systems be designed to recapture this spray water as runoff?

Certainly better uses of 5.33 million gallons per day can be found than spraying it on mounds of coal in an operation that might employ only about 200 people.

GPT: EIS Scoping Comment No. 14

Chuckanut Drive Landslide Hazard

The BNSF single mainline track south of Bellingham and below Chuckanut Drive follows a narrow passage between steep slopes on one side and water on the other. 

This particular corridor has a long history of landslides, which periodically block both State Highway 111 -Chuckanut Drive- and the railroad, requiring traffic delays and emergency clearing of both routes before vehicles or trains can proceed in either direction.

Because the geology of the Chuckanut Mountains contains formations of Chuckanut Sandstone that are frequently layered at angles tilted down slope, this represents an extremely hazardous situation that is conducive to landslides, especially in wet weather.

If a blockage due to landslide or other factors were to cause a train derailment occurrence in this narrow and relatively inaccessible corridor, how would this be handled in terms of clearing the railroad right-of-way? 
How would multiple carloads of coal dumped on the shoreline be cleared, and with what impacts on the water and other rail traffic, including AMTRAK passenger trains?

What special emergency services would be needed to rescue any injured people, and how would these be deployed and paid for?

Since this corridor is very constricted with limited platforms capable of supporting cranes and other lifting devices, how would disaster response be provided?

This problem needs to be treated as an integral part of the EIS Scope, and a comprehensive Hazard Response Plan developed to satisfy the important need for public safety throughout the recognized zone of influence of the GPT proposal.

GPT: EIS Scoping Comment No. 13

Coal Dust Clouds?

There have been repeated reports of sightings from boats traveling in Rosario Strait, of dense, dark clouds that appear periodically from north of Point Roberts.
These are suspected to be emanating from the coal terminal in British Columbia, which has troubling health-related implications should the much larger GPT facility ever be built here in Whatcom County.

The MAP Team needs to have these reports checked out to confirm if these dust clouds are, in fact, coal dust, and if so, to utilize that qualitative information to inform its EIS evaluation accordingly.

The GPT Applicants claims that dust suppression methods -including partial enclosures, baffles, negative pressure ventilation with bag filters, and water sprays- it plans to use will effectively prevent such dust clouds from escaping its premises, however these claims do need to be independently verified by competent authority to insure the Applicant's claims are accurate.

Only by quantifying the amount of coal dust generated from trains, violent car dumping, operation of stacker-reclaimers, multiple conveyors and conveyor transfer towers, and ship loaders, plus solids recovered from storm water treatment systems, will we know the extent of dust problems likely to impact the public and the environment.

GPT: EIS Scoping Comment No. 12

Purpose = Need?

Chapter 3 of the GPT Application document describes 'Purpose & Need', citing several national, state and local policies, plus international commerce, as the justification. 
It further asserts that GPT would purposely advance the economic development and environmental protection goals of Whatcom County, which stretches credulity and needs to be demonstrated to the public by a comprehensive cost versus benefit analysis, a cumulative & programmatic environmental impact analysis, a thorough health impacts analysis and completed studies on vessel & rail congestion and hazard safety.
Only when these studies are done and evaluated, can we know whether GPT actually will benefit anyone other than the Applicant and its associates.
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Section 3.2.1 claims GPT would meet three principal needs;
1. The need to ship bulk cargo to and from Asia and other markets to meet current and future market demand;
2. The need for deep water, bulk marine terminals in the Puget Sound region; and
3. The need for community and economic development in Whatcom County consistent with the Whatcom County Comprehensive Plan for the Cherry Point Industrial UGA.

It seems curious that each of these three 'needs' also extend into national and world affairs, yet the Applicant insists that for EIS purposes, their 'site' should limited to only a 350 acres footprint, despite clear reliance upon greatly increased levels train and vessel to and from GPT to achieve its goals. 
It would be inconceivable to ignore these certain, extremely widespread and admitted impacts in any honest EIS evaluation or determination!

Pacific Rim markets are intended benefit from GPT by receiving bulk commodities from the US, with coal exports accounting for by far the greatest volume.
It seems strange that GPT cites economic growth and improvement in the quality of life and life expectancy in Asia has created large demands for these commodities, with demand predicted to remain high for the long term. 
This appears to say that Asia benefits more than we do from GPT operations, a conclusion that may well be true.

Section 3.2.2 states we need for another Multi-Modal Deep-Water Bulk Marine Terminal in the Puget Sound Region, because the others are in urban areas, crowded and oriented to containers, not  bulk. 
Of course this need serves mainly GPT's purpose of creating a large Asian market for US coal.

The clearest statement about this need is the following:

The proposed Gateway Pacific Terminal would help meet the need for deep-water bulk marine terminals that have the ability to effectively and efficiently transfer cargo between overland and waterborne modes of transport in the Puget Sound region.

Section 3.2.3 further describes the Need for Community and Economic Development by citing US Government and Washington State adopted policies and initiatives to expand interstate commerce and export trade. 
It also claims consistency with various other plans and goals, which may or may not be exactly true.

Section 3.2.4 talks more about the need for an appropriate site to achieve GPT's goals, that is very large and able to efficiently accommodate large numbers of unit trains and large marine vessels almost without restrictions.
Does this really describe something that is likely to be compatible with the kind of community we are now and want to be in the future?

Let's complete the required studies as thoroughly as possible, then we'll see our options more clearly.
The needs stated merely serve to support the Applicant's purpose, not necessarily ours.
What is the rush when something with so many potentially harmful impacts is seeking approval?

GPT: EIS Scoping Comment No. 11

Bulk Carrier Vessel Concerns

As a former Helmsman and Navigating Quartermaster in the US Navy, aboard the Presidential flagship -the USS Northampton CC-1- I still have hair-raising memories of first-hand experience in the problems routinely encountered by Navy ships, especially in restricted waters around harbor entrances, sinuous passages, and ports. 

Other than the sometimes enormous difficulties wrought by wind, weather, currents and tides, the danger from other vessels - particularly foreign registry merchant vessels or fishing boats- is a constant problem, which the Navy very frequently deals with by taking extraordinary efforts to evade collisions or other in extremis situations. 

Too frequently, having the right-of-way doesn't automatically mean safety, because -like driving a car- the main problem is often the other guy, and what he's doing.

One big difference is that in open water on the high seas, there aren't stop-lights or traffic cops to enforce the law; only prudence and -as the USCG says- eternal vigilance, both of which can easily be missing.

Merchant vessels, particularly those that continuously transit oceans, seas, large gulfs and channels, often set their auto-pilots even before clearing congested or dangerous waters. 

That means no one qualified is always in charge of looking out for potential harmful conditions, especially with other vessels. 

The situation can be further complicated by crews, tired of overwork on relentlessly long and often boring duty, many of which do not speak english or have the skills necessary to read charts, use electronic navigation devices properly, or make simple calculations to determine whether their course and speed through the water might closely intersect with that of other vessels. 

Neither are the crew members on duty always qualified to take or recommend prudent evasive action to remove their vessel from harm's way. 

These combinations of factors too often add up to serious potential danger, even if weather conditions are otherwise ideal. 

When heavy fog, driving rain or sleet, high winds, big waves, tricky currents and abnormal tides enter the picture, the potential for problems is greatly exacerbated, often leading to collisions, spills, fires, near-misses, groundings, sinking, confusion for other vessels, and a major load for the US Coast Guard to oversee and provide assistance.

While very large vessels do usually have highly trained Masters [who can sometimes become incapacitated] and Owners who are adverse to expensive casualties from accidents, these alone do not insure against disasters, as the Exxon Valdez [whose Master was drunk] and other enormous vessels have vividly demonstrated from time to time at unexpected intervals.

The Salish Sea and the San Juan Islands simply cannot bear so many real and predictable threats, and should not be offered as sacrificial lambs on the altar of unrestricted commerce.

The Vessel Traffic Hazard Study is a exceptionally critical document that needs to be timely completed, vetted and opened to full public review before any level of approval is granted to SSA-Marine's GPT Application.

GPT: EIS Scoping Comment No. 10

Waterfront Redevelopment

For several years, the City of Bellingham and the Port of Bellingham have been planning a very ambitious -and expensive- Redevelopment of the former G-P industrial property and adjacent areas on the Waterfront which contain various levels of contamination deemed potentially harmful if they are left un-remediated.

Both the Port and City have committed significant resources toward the Waterfront Redevelopment effort, which holds remarkable promise in creating a very desirable area to enable building new businesses, institutions, residences and recreation areas for wide public use.

To enable this, millions of public dollars will need to be spent on clean-up, infrastructure and reliable waterfront access, with significant funds already spent or committed to this effort.

Upon completion, likely to require 20 years or more, this new 'neighborhood', adjacent to the existing downtown, is expected to accommodate businesses providing between 2500 and 4800 new jobs and over 2000 new dwelling units to house future growth.

Additionally, this venture is intended to make the Waterfront 'Bellingham's Front Door' by providing a clean, accessible, waterfront area designed to sustainably attract businesses, tourists and area residents interested in shopping, recreating and generally enjoying a great gathering space for multiple activities.

Converting this former, uninviting industrial area into a very desirable spot requires not only years of hard work, vision and funding, but insuring against unanticipated changes in events likely to be detrimental to it, like more than doubling the rail traffic that separates the Waterfront from the downtown and residential areas.

It is hard to imagine an unanticipated event that could be more harmful to the goals of a successful Waterfront Redevelopment than the sudden addition of 18 unit coal trains per day, each 1.5 miles long, blocking necessary road crossings, blaring high decibel noise and spewing diesel fumes and dust into the air.

What tourist, shopper, business owner or resident would consciously wish for such a round-the-clock nuisance?
Certainly no one that I know!

Even if grade-separated crossings were possible, they would likely be prohibitively expensive and take years to build, since there are more than a dozen of these, alone, within Bellingham's City Limits.
An average cost per bridge might approach $10 million, providing sufficient space is available and could be acquired.

That is a very large burden to impose upon any municipality and ought not to be allowed, particularly for selfish and arbitrary reasons.
Even with substantial mitigation, providing that is possible, the imposition of 18 additional very long trains per day, is a hurdle that threatens the very viability of the entire Waterfront Redevelopment Project.
That is simply unacceptable!
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GPT: EIS Comment No. 9

Financial Underpinnings

I have some concerns over the long term financial underpinnings upon which the GPT proposal is based, notwithstanding the deep-pocketed backers including Goldman Sachs. 
 The GPT proposal seems a distinct major departure from prior projects undertaken by SSA-Marine, one so ambitious that is expected to practically double SSA's reported annual revenues.
 Every such venture has a 'pro forma' basis for it to be seriously considered for advancement and undertaken, and so must GPT, with its reported corporate secrecy and opportunistic aggressive operating philosophy and lack of management experience in building and operating a large bulk terminal with the potential of creating so many collateral social, environmental and economic problems. 

What underlying assumptions are baked into this proposal that make it so attractive to the investment partners, besides a quick payout and avoidance of liability? 

What is GPT's best case scenario? A 10-year, or better, payback?

At what point would the idea become so much less attractive that the proposal would simply be withdrawn?
 Is GPT a truly long-term commitment to the economic health of our community, as is being claimed so loudly, or is it simply an opportunity to make a quick buck by flipping any favorable permitting result into a sale to another owner(s)?

Our community needs to know these answers with some degree of certainty to make sure the expectations for jobs, increased local business activity and the generation of new tax revenues to support local government, is fully realized by both the public and the final decision-makers. 

This EIS Scoping is serious business and needs to develop some serious answers that we can count on, before we commit to GPT our hopes for economic, ecological and social improvement. 

It is the community that must live with these results, not some financier or executive sitting in privileged silence and opulence somewhere else!

My concern is that the GPT proposal is built upon a questionable foundation that sits upon these several variables, among possible others: 

• natural resource extraction of a relative low value commodity [something more worthy of  a desperate, third world country]

• volatile and fluctuating global prices  [risky and often resulting in a race to the bottom]

• a 19th century technology that is known to have harmful impacts worldwide  [a step backwards into history that arrogantly disregards healthful common sense]

• a capital intensive method of transport logistics  [why ship relatively low value goods halfway around the world?]

• a business model that depends upon economies of scale and materials handling efficiency to compensate for an inherent lack of profitability  [a ticket to disaster, especially in the global economy]

• risky weather and other natural conditions that often and sometimes unpredictably threaten land, sea and air, often in sensitive areas  [very large, single hulled, single screw ships carrying a flammable cargo in dangerous conditions; a disaster waiting to happen]

• reliance upon foreign competitors to buy coal at prices that insure profits over a long time.  [a fool's dream]

• excessive focus on a low-tech business model that avoids other, value-added products and modern, domestic technologies that are much more likely to provide more good jobs and sustain our economy in the future.  [opportunistically shortsighted] 

• creating at least as many harmful and disruptive impacts as benefits, and externalizing these costs to others, including taxpayers, governments, businesses affected and future generations.  [not the sort of behavior normally expected of a good corporate neighbor]

• failing to understand the finite nature of our essential resources on this planet that must sustain us all.  [just plain stupid]

• buying into the flawed theory that indiscriminate, continual growth is necessary, good and unavoidable.  [the philosophy of a cancer cell; unsustainable, neanderthal thinking]

• deliberate denial of the environmental policies adopted by the States of Washington and Oregon, both of which have decided to phase out coal fired power plants. Shipping coal to China will mean the coal burned there will create the same atmospheric pollutants that harm us, without any benefits.  [willful ignorance and distain for policies and regulations deemed necessary for human and ecological health]

• forceful intrusion into areas and regions unprepared for the congestion and dangers inherent in massive unit trains and marine bulk carriers that threaten the very communities and sensitive environments they pass through on the way to foreign 'markets'.  [callous disregard for preservation of the planet and its people]

Surely, there are better business models for providing the same -or greater- benefits now being claimed by GPT.

What assurance can this community have that the present owners -SSA- will maintain ownership for the designed life of this facility [50 to 75 years], should it be built?