Read our full comments available online here.
- In 2010, the proponents sought permits from Cowlitz County to build a claimed 5 million ton/year project. After some Coalition members appealed that decision to the Shorelines Hearings Board, appellants uncovered confidential documents to expand dramatically as soon as permits were received. The attempt to defraud regulators led to national news and the withdrawal of this project. In our view, this event colors all of the claims that the proponents make about this project and its claimed benefits. It should not go unmentioned in this DEIS; via page 8.
- …the DEIS provides a discussion of accident risk in the Columbia River, we are puzzled by the DEIS’s decision to limit the scope of that analysis to three miles offshore; via page 9.
- We are also concerned that the issue of spill risk during bunkering is dismissed since the proponent promises not to bunker onsite. The promise simply begs the question of where will bunkering occur, as the vessels will not arrive from Asia fully fueled; via page 9.
- …buried in the middle of the DEIS with little emphasis is perhaps the single most significant number in the entire document: 90 million tons of CO2/year, which is the combustion GHG impact of the 44 million metric tons of coal that would come through the facility. DEIS 5.8-22. 90 million tons of CO2 roughly equals Washington State’s entire GHG emissions from all sources; via page 13.
- …the DEIS models marine vessels traveling from the U.S. to Asia, not return trips. The authors assume return trips would be laden with other goods and should therefore not be counted in this analysis. However, the DEIS fails to support this assumption, and there is ample evidence to support the opposite conclusion; via page 17.
- One major flaw infects all of the DEIS analyses related to rail. Buried in the DEIS is the surprising assumption that a 10% increase in “throughput” can be achieved from rail car capacity by 2028. DEIS at 5.1-4. It is not stated how 10% more coal will fit in the same size rail cars, nor is it at all self-evident; via page 20.
- The DEIS openly acknowledges that infrastructure on the BNSF Spur and Reynolds Lead is effectively incapable of handling the proposed increase in rail traffic due to capacity constraints. See, e.g., DEIS 5.16-16; 5.1-10 (maximum existing capacity of BNSF Spur and Reynolds Lead is 16 trains/day, and there is already traffic on it). Similarly, other components of the rail system cannot function with this project in place without significant upgrades. However, it further observes that there is a proposal to upgrade that infrastructure to accommodate the traffic, although that project is neither “funded or permitted.” DEIS 5.1-16; via page 21.
- A preliminary and significant flaw is that the DEIS uncritically accepts industry statements that surfactants are 85% effective at reducing coal dust, and that there is 100% compliance with using surfactants; via page 22.
- …the DEIS itself acknowledges that so much dust is produced by coal trains that it creates a safety hazard by destabilizing railroad ballast. DEIS 5.7-15; via page 22.
- Recent data from Australia backs up our concern that “real world” measurements do a substantially better job predicting what will happen than the models used in the DEIS. In a recent study in Australia, monitors showed dramatic spikes—including spikes that exceed levels set to protect human health and safety—when uncovered coal cars passed by. One particularly startling finding of this study was that empty coal trains had higher particular pollution than loaded ones. However, the DEIS dismisses pollution concerns from empty cars, an omission that must be rectified in the FEIS; via page 23.
- The DEIS relies heavily on one field study conducted over two weeks in October 2014 that found relatively small amounts of coal dust pollution and deposition, lower than a similar peer reviewed study conducted by Dr. Jaffe. DEIS 5.7-7. However, little information is provided on variable background conditions (such as wind speed and other weather factors) that could affect the outcome, or other factors (such as whether the railroad was aware of the time and location of the study); via page 24.
- Among the more startling admissions of the DEIS is that the project will proximately cause a substantial increase in the number of rail accidents—a 22% increase statewide. What is not disclosed is any meaningful analysis of the potential safety, human health and environmental risks of such accidents; via page 27.
- What is undisclosed in the DEIS is how frequent operations of coal unit trains—among the longest and heaviest trains on the rail system— contribute to higher-than-normal degradation of rail infrastructure, increasing the risk of accidents. Given the desire to substantially increase the amount of crude oil on the regional rail system, the DEIS needs to look closely at the extent to which the project will contribute not just to accidents generally but to crude oil accidents specifically; via page 28.
- According to the DEIS, MBT would generate more deep-draft vessel traffic than any single public port in the Columbia River Basin. DEIS at 5.4-18–19; via page 33.
- …several MBT mitigation measures contain undefined language with no clear path to ensure compliance. MM CDUST-3, “Reduce Coal Dust Emissions from Rail Cars,” is a poster child for the weak and undefined mitigation that characterizes MBT’s fish mitigation. Under this mitigation measure, MBT “will work with rail companies to implement advanced technology for applicants of surfactants along the rail routes for Proposed Action-related trains.” If MBT is aware of “advanced technology,” the applicant should identify this technology in the DEIS, the Co-leads should analyze the efficacy of the “advanced technology,” and the Co-leads should require MBT to utilize this technology. As a practical matter, MM CDUST-3 reads like other mitigation measures: weak, undefined, and potentially meaningless; via page 46.
- In addition to 75-acres of unenclosed coal piles, MBT proposes enclosing only 4,900 linear feet of the 16,100 linear feet of conveyor belts; via page 49.
- The DEIS relies on Coal Dust Technical Report in describing the impacts of coal dust on water quality and aquatic life. Both the DEIS and the Coal Dust Technical Report fail to examine studies published after 2005; via page 49-50.
- …the HIA [Health Impact Assessment] is an important tool for decision makers and must be made available so the public can review and comment on it. Scoping for HIA was not completed during the DEIS comment period. The public must be provided the opportunity to comment on a draft HIA before a Final HIA and a Final EIS is released; via page 53.
- Lindsey Sears re-ran the modeling that ICF did for the DEIS exactly the same except filling in the receptor grid to includ the facility and the Columbia River. The results as reported in Table 1 show that the Terminal will violate the PM10 24-hour, the PM2.5 24-hour and the SO2 1-hour NAAQS. The PM10 level is over twice the NAAQS. The PM2.5 level is nearly twice the NAAQS and the SO2 level are over 25% above the NAAQS.” via page 57. See page 58 for Table 1.
- Cumulative rail projects will impact many at grade crossings in Spokane County. Some will be closed for almost seven hours a day. DEIS 6-52; via page 68.
- The DEIS acknowledges that the cumulative impact of all the fossil fuel projects will be 110 rail accidents per year, with twelve of them attributable to the MBT project. Is Washington really willing to trade a coal or oil train accident statewide every three days for the benefit of serving as a transit point for fossil fuel companies?; via page 68.
- …while dismissing coal dust pollution on nearby homes and businesses as at worst a “nuisance,” the DEIS neglects to quantify the economic impact of coating homes and businesses with coal dust, or potential liabilities for the County if such harms become actionable; via page 72.
