Key DEIS Findings:
Over 200,000 Comments Received—Most expressing concern
- “The co-lead agencies received over 217,500 comments on the Proposed Action during the scoping period. Many of these comments expressed concerns about the Proposed Action.” Summary at S-9. Top three concerns: climate, salmon and water quality, and health impacts. Summary at S-9.
Greenhouse Gas Emissions
- Life-cycle greenhouse gas emissions from the project are equivalent to over seven coal-fired power plants. At full capacity, the DEIS concludes the project could produce 27 million tons/year net CO2 emissions.
- Table 47 at the Greenhouse Gas Appendix is critical, its available here: http://www.millenniumbulkeiswa.gov/assets/mbtl_technicalreport_greenhousegas.pdf. Table 47 provides a range of different scenarios and the impact under each. At the scenario where coal prices are highest, it finds huge impacts: 27 million tons/year net CO2 emissions. Key takeaway: this project will not be built unless coal prices increase.
- DEIS concludes that greenhouse gas emissions outside would be driven primarily by coal combustion in Asia and the United States. Across the four coal market assessment scenarios, emissions greatly vary. Under the preferred 2015 Energy Policy scenario, the change in emissions, or the net annual emissions, from the Proposed Action in 2028 would be 3.2 million metric tons of CO2e. This is equivalent to adding about 672,100 passenger cars on the road each year. The total net emissions for the preferred 2015 Energy Policy scenario from 2018 to 2038 would be 37.6 million metric tons of CO2e. DEIS at S-38.
Mitigation Cannot Eliminate Significant Adverse Impacts
- “If proposed mitigation measures were implemented, impacts would be reduced but would not completely eliminate significant adverse impacts resulting from construction and operation of the Proposed Action.” Summary at S-2. Section 7 describes “significant unavoidable impacts.”
Coal Dust Impacts Near the Terminal
- Table 6-21 shows violations of the National Ambient Air Quality Standards (NAAQS) for particulate matter (PM2.5) from coal dust in Cowlitz County.
- “The estimated maximum monthly coal dust deposition along the BNSF main line in Cowlitz County would exceed the trigger level for certain residential receptors (Table 5.7-7).” Chap. 5 at 5.7-21.
- “[R]esidents who live along the main line could experience nuisance levels [of coal dust] which may visible soiling on window sills, outdoor furniture, and other property.” Chap. 5 at 5.7-21.
- “The average and maximum deposition of coal dust on the BNSF main line in Cowlitz County was estimated to be above the nuisance thresholds at 50 and 100 feet, and because no state or federal standards apply, this an unavoidable but not significant impact.” Chap. 5 at 5.7-25.
Coal Dust Along Rail Route
- “Day-to-day rail operations could release contaminants to water resources immediately adjacent to the rail line, resulting in the potential for water quality impairment from increased rail transportation.” Summary at S-24.
Rail Traffic Impacts
- “Trains related to the Proposed Action could affect accessibility to community resources and public services during peak travel times because of increasing wait times at grade crossings along the Reynolds Lead, BNSF Spur, and BNSF main rail line.” Summary at S-12.
- “Trains related to the Proposed Action would also increase emergency vehicle delay at rail crossings. The total gate downtime would increase over 130 minutes a day at crossings along the Reynolds Lead and BNSF Spur, and up to 20 minutes a day at the study crossings along the BNSF main line.” Summary at S-32.
- Table 6-6 shows every segment on the rail system greatly over capacity if all proposed projects, including coal and oil, are built.
- Table 6-7 shows a significant increase in train accidents (this analysis includes oil trains).
- Table 6-9 shows unacceptable level of service at multiple rail crossings due to delays from cumulative projects.
Impacts to Tribes
- “Operation of the Proposed Action would result in impacts on tribal resources through activities related to the Proposed Action causing physical or behavioral responses in fish, or affecting aquatic habitat. These impacts could reduce the number of fish surviving to adulthood and returning to areas upstream of Bonneville Dam, thereby affecting the number of fish available for harvest by the tribes.”
- Increased rail traffic could delay tribal fishers access to fishing sites. DEIS Tribal Resources Fact Sheet at 4.
Example of Unenforceable, Speculative Mitigation
- The DEIS contains recommended mitigation measures. Many are unenforceable and speculative. For example, to address the impacts of coal dust from trains, the DEIS states: “BNSF should conduct a dust monitoring study along BNSF main line in Cowlitz County to evaluate coal dust emissions from coal trains, and if necessary, take further actions to reduce such emissions.” BNSF is not applying for any permits for the Millennium project.
- “Mitigation” measures to address coal dust near the terminal include creating a system for people to report coal dust complaints. DEIS Coal Dust Fact Sheet at 4.
Power Past Coal Quote on the Millennium DEIS:
“The review's findings confirm what the public has said for over six years: This project has significant, unavoidable impacts--from toxic coal dust to greenhouse gas emissions to traffic delays,” stated Jan Hasselman, attorney for the Power Past Coal Coalition. “The Dept. of Ecology acknowledges that moving over 44 million tons of coal in uncovered trains and stockpiling it along the Columbia would harm people’s health and the river. The bad news is the review falls short, relying on unproven mitigation. Now is the public’s chance to weigh-in to say no to coal export in Washington.”
