GPT: It's Never Over, 'Til It's Over

It was probably someone like Yogi Berra who stated the obvious quote above, but he was right, not only above baseball, but other things as well.

The proposed Gateway Pacific Terminal [GPT] and the well-financed folks behind it are an example of something many people oppose for good reasons that seems to have a momentum all its own.
Our community and others have expressed serious concerns about this project and the impacts it will have should it ever come to fruition. Yet, like a ravenous stalking predator, it keeps coming back.

It's quite possible that the only solution to the dangers GPT represents can only be the purchase of the property and physically removing it from consideration as a major coal export site.
Depending upon the cost, that solution could well be much cheaper than the cumulative myriad costs of social and environment harms that would certainly be externalized to the public should GPT ever be permitted to operate.

But GPT is only one such self-serving venture, albeit the one closest to our community. There are many others, known and in planning that could impose similar harms.

Several months have elapsed since I last blogged on the subject of GPT and related topics, but fortunately several others have been following it closely and reporting what they've found.

Today's Crosscut carries Floyd McKay's latest report, entitled 'Coal exports from Bellingham could ramp up rapidly'.

I strongly suggest reading it.
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GPT: Footsteps to Oblivion?

August has already provided welcome news to all who have experienced serious reservations about the proposed Gateway Pacific Terminal to export coal.
Of course, consideration of that proposal must still go through due process, but now the playing field has been leveled considerably and a much more balanced weighing of pros and cons is likely.

Whether the current proposal fails won't determine what future proposals may come forward.
Even if the GPT site itself is eventually purchased and turned into a park or other restricted use, increased rail traffic to bring petroleum feedstocks to local refineries may become a reality.

Here are links to several articles that announce and explain recent developments:

• Bellingham Herald: http://www.bellinghamherald.com/2013/07/31/3121522/ecology-will-study-impact-of-coal.html

• Aftermath of DOE announcement: http://www.bellinghamherald.com/2013/08/01/3123889/roundup-of-items-in-the-aftermath.html

• Sightline Article: http://daily.sightline.org/2013/08/01/another-shoe-drops-for-gateway-pacific/

• Lummi Nation Letter to USACE: http://www.bellinghamherald.com/2013/08/02/3126384/lummi-nation-sees-no-compromise.html

• Crosscut Article by Floyd Mckay: http://crosscut.com/2013/08/01/coal-ports/115793/coal-port-faces-new-level-environmental-scrutiny/

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The price of freedom is eternal vigilance.

GPT: A Response to April 13 Bellingham Herald Article

As promised yesterday, here is my response to the following article, published in the April 13, 2013 Bellingham Herald: Terminal's family-wage jobs, taxes would aid Whatcom County(Authors: Brent Goodrich - Ferndale City Council and Bonnie Onyon - Blaine City Council)
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Article 1 of our Constitution ensures every citizen's right to free speech, including all manner of political or commercial speech that does not unduly malign either the public or other individuals.

Since both Mr Goodrich and Ms Onyon are not only citizens, but elected governmental representatives, what they have written doesn't appear to break any laws, except maybe those of good judgement and balanced accuracy. No, they are likely just expressing their opinions [wishes] while using their public status to influence others to support GPT, despite any drawbacks that plan may be found to have. 

I do find it interesting that the authors have admittedly reached their decision of unqualified support in advance - a priori - of completing the EIS evaluation; but maybe they think they know more than the rest of us, scientists and all? Maybe they do, but that seems highly unlikely.

As a retired Chemical Engineer and former elected member of the Bellingham City Council, I also have reviewed the GPT proposal in detail, and found enough insufficiently addressed or unanswered questions to cause major concerns for me as well as many others in Whatcom County and elsewhere.  A summary of 32 of these identified concerns can be found on the GPT EIS website listed under my name, for those interested.

The authors' un-equivocated acceptance of the most optimistic projections of job and revenue generation, happening immediately, also deserve much closer scrutiny! Perhaps, this factor alone explains their enthusiastic support for GPT, since no heavy lifting on their part is required for their respective municipalities to inherit large windfalls of heretofore unanticipated revenues.

Of course, these most optimistic projections are all predicated upon GPT being permitted, built and actually operated for decades; each of these steps are problematic at best. Even more important are the time delays implicit in the GPT timeline; the best projections will require 20 or more years before they might even be approached! Until that time, significantly less revenues would accrue to the Ferndale and Blaine entities expected (by the authors) to benefit the most from GPT. 

But, the other troubling aspect - entirely dismissed by the authors - is the lack of benefits accruing to other municipalities and entities that would be impacted by GPT and its related formidable array of supply trains and delivery vessels. That part, alone, is shocking, but don't forget yet another major omission, externalizing (ignoring) the costs of impacts on all municipalities and citizens as well as the local -and global- environment! 

In any business evaluation, a thorough cost/benefit analysis is a prudent, even essential, early step.

It's difficult to understand why the authors -and the proponents- would want to truncate this analysis and accept the additional risks to the public and environment that introduces, unless they consider their anticipated gains dwarf all other considerations. 

It appears the cost/benefit analysis these people propose applies only to the more limited local -and only positive- economics side of the equation, conveniently ignoring the equally important social and ecological considerations. For a truly sustainable venture to succeed, full-cost accounting (triple bottom line) is a necessity. That approach would provide a net benefit to everyone in the long-term, not just a few seeking quick, windfall profits and revenues at the expense of others.

Although the authors claim they've 'done their homework', they have miserably failed both the exam and the course! Did they not know that former WA Governor John Spellman, vetoed an earlier Cherry Point Terminal proposal over 30 years ago, stating that gaining a few jobs while badly degrading the environment was a bad trade-off that simply wasn't acceptable? In a Channel 9 interview on April 16, Spellman said he'd made the right decision then, and even though it did not benefit him politically, he'd make the same decision again - 'because it was the right thing to do'.

As the late Senator Patrick Moynihan once said, 'everyone is entitled to their own opinions, but not their own facts'. Let's be more careful of mixing up opinions with facts, because that practice can lead to very poor decision-making that will adversely impact us for many years to come. We citizens deserve consistently good decisions from our elected officials, based upon as thorough an understanding of facts  as possible, before personal opinions are expressed, and certainly before any permits are granted and potentially harmful applications are approved. 

If Mr Goodrich and Ms Onyon aren't up to this standard, why are they in office? Thank goodness they will not be the final decision-makers!

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.

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.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.

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: 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. 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. 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. 8

Vessel & Rail Capacity & Congestion

The very ambitious proposed GPT project depends upon a very large wharf and trestle structure that extends into a known, critical herring spawning area and is in close proximity to BP's existing petroleum loading pier, which supplies crude oil from Alaska and ships valuable refined products from the refinery to US markets. 
Soon, BP will need to expand this facility to accommodate additional crude and refined products shipping for US consumption.

I am concerned that the huge GPT wharf will constitute too much potentially dangerous ship congestion in that immediate area, as well as the narrow shipping lanes that provide water access to it. It is particularly troubling that the use intended by GPT is to ship large volumes of American coal to foreign powers and competitors, while burdening communities and citizens to deal with the offsite impacts. 

A similar concern applies to GPT's dependence on BNSF's rail capacity, which likely will become necessary to convey petroleum products.

Our natural resources, rail system capacity and deepwater access are valuable, and should prioritize those uses that are in our national interest.
Rather than have the GPT proposal absorb so much rail and maritime access capacity, a better plan would be to reserve these capacities for existing, sustainable and domestically important uses.

Coal: GPT EIS Scoping Comment No. 1 - Adding Insult to Injury

Incomplete Application

Today begins the official public comment period for the proposed Gateway Pacific Terminal's Environmental Impact Statement [EIS].
These may be sent by mail to:

Mr. Randel Perry, U.S. Army Corps of Engineers, Seattle District, Care of: GPT/BNSF Custer Spur EIS Co-Lead Agencies, 1100 112th Avenue Northeast, Suite 400, Bellevue, Washington 98004 

or via e-mail to comments@eisgatewaypacificwa.gov.

I certainly hope every concerned citizen will take advantage of this one opportunity to be heard!
Personally, I plan to submit my first comment later today. 
[see below]

Copies of all documents will be available at this website: www.eisgatewaypacificwa.gov  

The time for commenting will end on January 21, 2013, 120 days hence.
In between will come seven public hearings, with only two in Whatcom County:

• on Oct 27 at Bellingham's Squalicum High School from 11 AM until 3 PM, and

• on Nov 29 at the the Ferndale Events Center from 3 PM until 7 PM.

I take some encouragement from the fact that 5 public hearings are scheduled for other WA communities, including Mt Vernon, Friday Harbor, Seattle, Vancouver and Spokane.
This seems to acknowledge that impacts from heavy rail and ship traffic to and from GPT would be felt much more widely than just within the proposed terminal's footprint, as the proponents wish.
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Last Friday marked another annual season change, the Autumnal Equinox.
That marks the time when cooler weather and shorter days means harvest time is approaching, a necessary prelude to enduring winter challenges.

The early harvest SSA-Marine reaped Friday at the Cherry Point beach seemed to exactly fit what they have sown, toxic weed seeds that threaten the very way of life [Sche Lang en] for the Lummi Nation.
The Lummi name for their former Cherry Point area village is Xwe'chi'eXen, which is considered a sacred ancestral site, located near traditional fishing waters.

Resolution #2012-060 of the Lummi Indian Business Council, certified on June 19, 2012, registered their opposition to the GPT project proposed by SSA-Marine.
That sentiment was strongly conveyed at the Lummi gathering, attended by about 200 people that I witnessed last Friday.

If the GPT project itself is considered an injury, then attempts to buy Lummi support for it adds insult.
That was the clear message conveyed by ceremonially burning a replica of a very large check marked NON-NEGOTIABLE in red paint, with SSA officials looking on.

After wondering what the Lummi position would be, I was encouraged by this gathering and the unmistakeable public message that was sent to SSA-Marine.
------------------------------
A few published articles describe these recent events:

http://www.nwcitizen.com/entry/lummi-nation-opposes-coal-terminal - Local blog report

http://crosscut.com/2012/09/21/coal-ports/110640/lummi/ - Floyd McKay's report on Lummi gathering at Cherry Point

http://www.bellinghamherald.com/2012/09/21/2700524/lummi-nation-leaders-come-out.html - Report on Lummi gathering at Cherry Point

http://earthfix.opb.org/energy/article/wash-tribe-comes-out-against-coal-export-terminal/ - Lummi statement

http://daily.sightline.org/2012/09/19/fish-vs-coal/?utm_source=Sightline+Newsletters&utm_campaign=af6bfc296a-SightlineWeekly&utm_medium=email - 

http://www.coaltrainfacts.org - a valuable, one-stop resource

http://www.coaltrainfacts.org/scoping

http://www.nws.usace.army.mil/Missions/CivilWorks/Regulatory/PublicNotices.aspx - contains  Special Public Notice
and Notice of Intent to Prepare a Draft EIS

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Here is the comment I submitted today:

September 24, 2012

Mr Tyler Schroeder, Whatcom County

Mr Randel Perry, U.S. Corps of Engineers

Ms Jeannie Summerhays,  Washington State Department of Ecology

Subject: Scoping for Draft EIS for Proposed Gateway Pacific Terminal, Cherry Point, Whatcom County

As a long time Bellingham resident and former elected official, I am submitting these comments for the careful consideration of the MAP Team:

From reading the GPT Application Document submitted to Whatcom County Planning & Development Services on Feb 28, 2011, it is apparent that much thought has gone into its preparation. 

However, it is also apparent that much more additional, important information is required before this Document can be reasonably considered complete and is therefore ready for any sort of final evaluation or approval. 

This EIS Scoping Process will undoubtedly provide a number of questions that thoughtful decision makers will need to have answered to their -and the public's - satisfaction.

For example, to be fair, impartial and complete, I wonder why several studies that are referenced in the Application have not already been completed? 

Some of these studies are quite important, such as the Vessel Traffic Analysis, the Aquatic Species Study for the local herring stock at Cherry Point, a detailed Storm Water Collection & Treatment Plan for the entire terminal, an Analysis of Meteorological Data as it applies to surrounding population centers, Noise Studies, Vehicular Traffic Impacts outside the immediate site footprint, and the like.

Without being able to actually examine these studies, there is no way for the public to know what they contain or whether the data and conclusions are accurately derived and used or not! Is the public to accept verbal promises on faith in lieu of reviewing the actual studies?

As an unpaid citizen with no professional staff, I expect to have this potentially critical information available to me in a timely fashion so that I can review it and develop any important questions I might have, without risking that the time for commenting will run out before I finish. 

I certainly hope the Applicant -and the MAP Team- values the type of stakeholder that I represent, especially when a project like this one has the clear potential for unduly weighing against a fair cost -versus- benefit analysis.

I can think of no way this particular situation can be remedied, short of making the substantial relevant information timely available before any Final EIS is attempted. 

Please commit to seeing this course of action is followed before allowing the Public Scoping period to become a pre-ordained charade.

Very truly yours,

John Watts

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Energy: WAL-MART's Epiphany

It's been a while since I've written about WAL-MART, but here's a story that should appeal to those who consider our energy policy to be lacking and think big government policy incentives are the only way to fix it.
Guess what? 
Old fashioned good business sense can also begin to change our stupid reliance on only burning ever more fossil fuel. 

Remember the 'WAL-MART effect'? 
You know, the one which resulted from WAL-MART buying into the energy efficient light bulb idea, then switching its corporate policy to be the de-facto leader in that effort?
It worked! 
And its competitors followed -almost overnight.

Now, why do you imagine WAL-MART made that decision? 
Think it had anything to do with saving itself major electrical utility costs, like on the order of 30%?
Here's a flash; self-interest motivated WAL-MART, which then led to the idea that other companies might follow for the same reason. 
But, by trailblazing this inherently good idea, WAL-MART got the immediate attention of not only its customers, but its competitors, who seemed to need a little more motivation than just doing something smart because it was smart.

After that resounding success, WAL-MART -always cost conscious- followed by reducing its huge consumption of diesel fuel by making more smart changes, like shutting down its truck engines instead of leaving them to idle as had been the widespread custom.
That little idea saved 20% of fuel costs for WAL-MART's huge truck fleet.

The latest change in WAL-MART thinking is to generate its own energy from solar and wind power, as is reported in this recent article.
Read it if you dare!
Maybe WAL-MART can convince even more doubters that alternate energy makes both sense and dollars!

While I still don't shop at WAL-MART except occasionally, you can bet I'm getting closer to it.
Because when a company, already so good at optimizing its supply chain, begins to turn its attention at other effective ways to cut costs, watch out!
The reported 27% less cost for a typical grocery basket at WAL-MART isn't something to sneeze at, and neither are economies of scale.

Now, maybe the company will focus more on providing better wages & benefits and a greater selection of American made goods; when that happens, maybe I'll become a more regular customer.
These folks are not stupid; they're smart!
I'd like to see more businesses just get with this program.
Not only will it work for them, it'll work for all of us.
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GPT: Benefactor or Malefactor?

First, here are a couple of articles published recently about grandiose Coal export plans affecting our area; read 'em and weep:

http://earthfix.opb.org/energy/article/what-wyoming-coal-means-for-the-northwest-the-view/

http://earthfix.opb.org/energy/article/american-coal-companies-look-to-the-west-coast-for/
The second article quotes Bellingham's own Craig Cole, who notes that projects like this actually benefit the whole country and its economy. 
Do you agree with that? 
Wonder if he might also agree with associated harms that are caused, like environmental degradation and displaced societal investments and plans? 
Go ahead, ask him!
------------------------------

The sheer enormity and certain potential for major, permanent degradation is discouraging. 
Surely, there are better uses for this property. 
But, this GPT scheme is the proposal we have before us.

I have now added another link to allow access to the public information application the applicant submitted to Whatcom County Planning & Development Services [PDS] on February 28, 2011. 
This attempt to externalize costs and impacts onto to 'others' is very obvious from a reading of this application.
BTW, what degree of 'opacity' do you assign to GPT's public statements so far? 

It is a pdf document over 200 pages in length, which I have now reviewed pretty completely.
Predictably, I do have some fairly extensive questions and clarifications that need to be answered. These will be posted in due course, as specific concerns directly related to this application.

To date, the GPT conversation has been essentially one-sided, with the big money sponsors and their coterie of automatic cheering sections loudly touting the benefits while remaining silent on deleterious impacts. 
These are highly paid professionals whose goal it is to maximize corporate profits while minimizing the costs that will need to be paid from public coffers. 
Just understand that up front.

A large part of that strategy is simply limiting the scope to the basic footprint on the immediate property, while the entire logistics route, plus the mines and atmosphere are to be included.

Then, also, the mindset that GPT is that they are only a small of the assemblage of partners. 
This again, tests credulity!
GPT wants to be seen as a simple trading company tolling station that transfers products they will never own from one mode of transportation to another, with both representing potentially extraordinary impactful threats.
That also seems to apply to the financiers like Goldman Sachs who will only be interested in a quick assured payback with interest. 
Just take the money and run with no care about what ill effects the project may bring.

No one, single entity is identified that wants to accept responsibility for the totality of this operation, only its part of the profits and cost avoidance.
That is a pretty plain formula for fleecing the public; Baaa-a-a to that!
At a minimum, this secretive and devious consortium needs to be required to provide adequate insurance coverage to pay for any unplanned- but likely unavoidable- catastrophic mishaps. 
These can be single events or an accumulation of events and impacts that add up to unacceptable degradation to public lands, waters and air.

I know projects like this one are very expensive, but do carry the promise of creating jobs and wealth, because I have been involved in such proposals myself for many years during my corporate professional life. 
Unlike this proposal, the ones I was involved with assumed all responsibility for the operations and impacts, as affected governments and public entities realized the necessity for the venture.

There is no necessity for GPT, only the wish for quick profits from transferring enormous quantities of a domestic natural resource into 'black gold' for foreign competitors. 
This kind of motivation is no justification for it to happen at all, especially since it also brings the prospect such ruinous impacts to existing communities, our waters and atmosphere.

In the spectrum between wants and needs, this is clearly a want! 
Where on that scale would you rate it?
That also goes for the phalanx of fawning toadies who think they stand to benefit from this venture going forward. 
They are clearly thinking of themselves first, and not for what may be best for our collective lives together on this planet.

As far, as opposition to GPT goes, that has been either discouraged [think Whatcom County Prosecutor's Office] or derided as simple NIMBYism. 
What is that about? One side is allowed free acceptance and unlimited bloviation, while opponents are discredited, even though their arguments need to be heard.

Like a growing proportion of people who live here, I was drawn as much by by the area's breathtaking beauty as I was by the prospect of a local job. 
The job was a means to an end, not the end itself! 
Even that job was a victim of excessive corporate greed and unsustainable mis-management! 
When it ended, I elected to stay here anyway because my situation allowed it. 
Now, I'd like to stay here longer, but developments like GPT do tempt me to move somewhere else; wouldn't that be convenient? 
But whether I live here or not, this is my neighborhood and I have very serious doubts that GPT will be good for anyone's backyard in the long run!

Mark Twain lived in the Gilded Age, and loved it because -gifted as he was- he liked getting rich quick. 
He liked that so much he did it several times, often losing everything by gambling on a risky scheme. That was the latter half of the 19th century, the period of robber barons and industrial titans, who could care less about anything other than their own wealth, opulent and wasteful livestyles and power. 
Is that what we want to happen again? 
Isn't that type of excessive selfish motivation at the root of many of our current problems? 

That was also the time when railroad tycoons did what they wanted and were richly rewarded by our government with land and riches beyond belief! 
Guess what? Surprise, surprise, they want to continue that status! 
That was the time when corporations -then called 'trusts- began to be considered as people. 
Look where that idea has gotten us. 
Of course, the roots of the idea that money was 'speech' was also the wish of the tycoons. 
Some even used their money to buy seats in our Congress. 
Imagine that!
Like the idea of money from somewhere else determining what happens in your backyard? 
If so, you'll probably also love GPT!

What will happen to all that capital spent to finance GPT? 
Will it be repaid with handsome interest to wealthy individuals who may decide to invest it outside our tax laws, in Switzerland, the Cayman Islands or the Bahamas? 
How will that help us finance our essential services and other needs for the future? 
Does anyone really believe that the taxes generated from operation of GPT will be even close to sufficient to pay for the increased public services required, or the infrastructure costs? 
How did Judas spend his 30 pieces of silver? 
Think he enjoyed it? 
How about his offspring -if he had any?

GPT estimates its 'life' at 50 to 75 years, which may become shortened by a number of reasons; no more coal supply or demand, lower than anticipated prices and profit margins, global climate events that convince us that fossil fuels are the source, catastrophic accidents that destroy or materially damage important ecosystems, war & terrorism, public dissatisfaction with having to pay for private gain with public resources, improved regulations, poor business decisions, [you fill in the blank].

The point is, when GPT's time is up, the deleterious impacts will remain; just like we've seen happen before at Georgia-Pacific on our downtown waterfront. 
A Superfund type mess for us to deal with at public expense. 
When the herring, salmon and Orcas are gone, then where will the fishermen and tourists go? 
When railway communities become modern versions of shanty towns, who will buy the real estate? When the spike in economic activity based on resource extraction winds down - again, where will people find work? 
And, when this area becomes known as no longer so breath-takingly beautiful, who will care? 

But, maybe, just maybe, none or not all of these dire predictions will come true? 
Are we willing to take that chance? 
We will be doing that unconsciously unless we fight GPT now and hold it to the highest standards possible!

In the meantime, please remember the warning that President Teddy Roosevelt -a Republican- gave us a century ago when he was faced with the mounting power of the corporations -combines & trusts in gentler talk- in his time. 
He used the term 'malefactors of great wealth' as representing a serious threat to our entire system of government, then took strong action to curb that power.
That particular problem has the characteristic of periodically reappearing from time to time, as it has again now. 

So, you decide, does GPT look more like a 'benefactor' or a 'malefactor' to you? 
Maybe some of both? 
If so, let's make sure we balance the beneficial factors against the harmful factors, before allowing this ambitious get rich scheme to come to fruition in our time. 

Do they seem completely clear and honest? 
Does their application need to be seriously conditioned? 
If so, in what ways?
And, most important, what is going to be your role in making sure the EIS is scoped exceptionally well? 
Will you submit a concern? 
Will you monitor the proceedings to the best of your ability? 
Will you make sure your elected officials understand your expectations?
I hope so, because that is about all we can count on to insure what happens is above board, well considered and the best decision we can reasonably expect.
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