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: http://climatesolutions.org/nw-states/coal-train-study
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.

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.

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.

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.

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.

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. 

Really!

 

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.