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.
Tuesday, November 27, 2012
Monday, November 26, 2012
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.
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.
Tuesday, November 20, 2012
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!
Thursday, November 1, 2012
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.
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.
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
Misuse of U.S. Coal Resources
=============================
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:
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.
Tuesday, October 30, 2012
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;
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.
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.
(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.
----
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.....
Monday, October 29, 2012
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.
----------------------
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.
---------------------------
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.
--------------------------
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.
----------------------
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.
---------------------------
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.
--------------------------
Friday, October 12, 2012
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.
---------------------------------
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.
5.3.3 Effects of Operation on Marine Resources
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.
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.
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!
--------------------------
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:
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.
---------------------------------
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
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
5.3.4 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, 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).
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!
--------------------------
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:
Thursday, October 11, 2012
GPT: EIS Scoping Comment No. 18
GPT: The Liability Labyrinth Linchpin
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.
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.
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.
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?
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?
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.
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.
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.
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.-----------------------------
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:
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.----------------------------
Wednesday, October 10, 2012
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.
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.
Tuesday, October 9, 2012
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.
---------------------------
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.
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......
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.
----------------------
Monday, October 8, 2012
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.
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.
Sunday, October 7, 2012
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?
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.
Saturday, October 6, 2012
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.
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.
Friday, October 5, 2012
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 would be inconceivable to ignore these certain, extremely widespread and admitted impacts in any honest EIS evaluation or determination!
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.
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?
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