Submission Number: MBTL-EIS-0000354
Received: 9/29/2013 11:54:19 PM
Commenter: John Covert
Organization: Citizens for Sensible Transportation Planning
Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
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Statewide, BNSF railroad has 524 “at Grade” rail crossings that have gates and/or warning lights (so called ‘Active Protection’). See attachment. Union Pacific has 100 “at Grade” crossings. The eis process needs to identify which rail lines and which “at Grade” crossings are going to be used to transport coal from the mines to the terminal(s) in Washington or elsewhere. Will trains be allowed on the entire railroad network or will they be restricted to certain lines? If they get diverted onto unauthorized lines, what is the penalty? The scope can’t be limited to coal going to just one terminal. We need to understand the impacts across the board at its broadest implications for our country. If I am stuck in traffic at a railroad crossing in Spokane County because a coal train is going by, I don’t care where its ultimate destination will take it. Stuck in traffic is stuck in traffic. The increase in traffic congestion created by the additional trains being added to the existing rail network needs to be identified and properly mitigated. Transportation projects under construction in just Spokane County are spending billions of dollars to add capacity to the transportation road grid and this project is going to increase traffic congestion on dozens of arterials that cross rail lines at “at Grade” crossings.
Adding this congestion to the grid is contrary to the Washington state Transportation Implementation Plan and is not authorized in the SRTC Transportation Improvement Plan. How is it legal for a project to create as much congestion in the road network at the local level and at the state level as this project is going to create?
Some news reports suggest as many as 63 additional coal trains per day will enter/leave Washington state through the Spokane area. Others suggest the number of trains per day will be less than 10. There is widespread uncertainty about the maximum number of trains. The eis needs to clarify the maximum number of trains that will be necessary to move the projected maximum volume of coal. Future traffic congestion impacts need to be evaluated based on the maximum build out. The cost of the increased congestion created by the additional volume of rail traffic needs to be calculated. When the state of Washington transportation department estimates the cost of congestion, they use an estimate of $21.90/hour per hour of congestion (WSDOT 2012 Congestion Report). In Spokane County, on just the BNSF rail line to Pasco, there are 25 “at Grade” crossings. See attachment. The average daily traffic count for these roads is more than 51,000 cars per day. A portion of this traffic volume will be subjected to increased congestion for so many minutes per day as the additional train volume traverses the county. This will lead to several hundred hours of delay per day of increased congestion. Over the course of a year, this will cost Spokane County drivers over one million dollars in increased congestion (at $21.90/hour). The additional delay added to the road grid will cause emergency medical transportation delays in getting sick/injured people to hospital emergency rooms. It will create additional delay transporting children to schools, and workers to their jobs. These impacts also need to be evaluated under future, modeled traffic counts for the life of the project. These impacts need to be evaluated and mitigated. These types of issues will need to be addressed along the entire length of the rail grid that will move the additional coal supplies.
According to the Federal Railroad Administration, in Washington state between 2008 and 2011 there were 86 highway-rail accidents reported at public crossings on public roads. 19 fatalities were reported during that time period. As the number of trains increases, the number of accidents and fatalities is likely to increase. These impacts need to be evaluated in the eis.
An article in the August, 2007 Journal of the American Board of Family Medicine says that on an equal horsepower basis, diesel exhaust is 100 times more toxic than gasoline exhaust, even when carbon monoxide is considered. The study also identifies proximity to rail lines as a source of clinically significant exposure to diesel exhaust. In 2006 the California Air Resources Board estimated that diesel exhaust pollution directly accounts for 2400 deaths and, annually, nearly 3000 hospital admissions for respiratory and cardiac-related diseases, at a total cost of $19 billion in California alone. With the potential of 60+ additional trains each day in the Spokane area (~240 diesel locomotives) the impacts of the additional diesel exhaust on the health of people residing in the airshed also need to be evaluated.
The eis needs to fully analyze and explain to the public what the implications are for this project and its increase in rail freight volume moving through our communities.