Tuesday, October 9, 2012

GPT: EIS Scoping Comment No. 16

Climate Change: Who's Responsible?

The GPT Application Chapter 5.7 Air Quality - Section 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 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.
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.