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.