Submission Number: MBTL-EIS-0001652 

Received: 10/19/2013 3:37:00 PM
Commenter: Ron Lindsay
State: Washington

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
Attachments: No Attachments
Submission Text
From:Ron Lindsay <> Sent:Saturday, October 19, 2013 3:37 PM Subject:Comments on Docket Number 2013-19738
Dear U.S. Army Corps of Engineers, Washington Department of Ecology, and Cowlitz County Commission,
Dear U.S. Army Corps of Engineers, Washington Department of Ecology, and Cowlitz County Commission,
RE: Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk Terminals Longview LLC Coal Export Terminal
Millennial Bulk Terminal Statement
My name is Ron Lindsay and I am a climatologist. I work at the University of Washington in an office called the Polar Science Center. I have worked on research about Arctic climate for forty years using field work, a wide variety of satellite data, and numerical modeling to analyze and understand the changes that are occurring at high latitudes. When I started my career I had no idea that in my lifetime we would see such dramatic changes in Arctic climate and sea ice. We now see late summer sea ice extent has diminished by 40% since 1980 over an area comparable to that of the entire United States. This is a vast and unprecedented change not seen before in human history. I personally have no doubt that this long-term trend in summer ice extent is primarily caused by the burning of fossil fuels and deforestation. While there are large uncertainties in projecting sea ice decline due to unpredictable natural variability and model uncertainties, I believe the summer ice will be essentially gone by 2040 +/- 20 years. Exactly when it will be gone is uncertain but there is little doubt it will be gone later this century, regardless of what humans now do.
But what does this have to do with coal terminals? I believe it is essential for the Environmental Impact Statement for the Longview Terminal include the total cumulative impact of all Pacific coal ports over the entire life of all of the projects. Why?
Carbon dioxide created by burning fossil fuels stays in the atmosphere and ocean for many centuries. Carbon dioxide flows into and out of the ocean and biosphere in the natural breathing of the planet and CO2 that is dissolved in the ocean, contributing to ocean acidification, can be easily released back to the atmosphere. The atmospheric concentration of CO2 cannot markedly decline until the CO2 in the ocean has once again been captured by living organisms and sunk to form deposits on the ocean floor to create new rich coal and oil deposits for a civilization many millions of years hence.
This means that climate changes caused by carbon dioxide are expected to persist for many centuries even if emissions were to be halted now. It does not matter much how rapidly we burn the fossil fuels, what really matters is the total carbon released. The world has entered a new geologic epoch, the Anthropocene, in which human activities will control the future evolution of Earth’s environment in substantial ways. Carbon emissions during this century will essentially determine the magnitude of eventual impacts and whether the Anthropocene climate impact is a short-term, relatively minor change from the current climate or an extreme deviation that lasts thousands of years. The higher the cumulative carbon dioxide emitted and the higher the resulting atmospheric concentration, the higher the peak warming that will be experienced and the longer the duration of that warming will be.
This fact has been highlighted in the recent IPCC 5th Assessment Report: A large fraction of anthropogenic climate change resulting from CO2 emissions is irreversible on a multi- century to millennial time scale, except in the case of a large net removal of CO2 from the atmosphere over a sustained period. Surface temperatures will remain approximately constant at elevated levels for many centuries after a complete cessation of net anthropogenic CO2 emissions. Due to the long time scales of heat transfer from the ocean surface to depth, ocean warming will continue for centuries. Depending on the scenario, about 15 to 40% of emitted CO2 will remain in the atmosphere longer than 1,000 years.
But to be clear, the total carbon export from the proposed Pacific terminals, perhaps 100 million tons per year for 50 years, or 5 trillion tons, is a small fraction of total global carbon emissions and global coal production. But the impact will be far from negligible. Think not only of the specific impact but the manner in which the coal from these terminals must fit within fixed regional, national and global total carbon budgets.
The IPCC has called for a cap of about 1000 trillion tons of cumulative carbon emissions for the entire globe and we have already emitted about half of that quantity. These terminals alone could contribute a full 1% of the 500 trillion tons the entire globe can emit in all future years. The carbon budget for the United States must be just a fraction of that 500 trillion tons and we know there are very large portions of that fraction that are already committed. Should a few coal companies be responsible for a large portion of the increases in global and US carbon budgets?
The US must develop a carbon budget within an international framework to prevent catastrophic climate change. The scope of the EIS must include an accounting of exactly how the proposed maximum total cumulative coal exports from all Pacific coast terminals will fit within regional, national and international carbon budgets. Consider what parts of these budgets are committed…not subject to reduction…and discretionary…what has not yet been committed to. What fraction of the US discretionary new carbon emissions would these terminals be responsible for? The distinction is important. Much of our current carbon emissions are very difficult to reduce and our best bet is to try and stop any new massive sources of fossil carbon. How exactly do these terminals fit within likely US budgets for new carbon emissions? If the emissions are to be included in the carbon budgets of other countries (which might make sense within an international agreement), how will this be implemented and in forced? It is in the national interest to know what our carbon budget is before committing to massive new carbon expenditures.
Please consider postponing all the port projects until the US can establish a legally binding national and international carbon budget and a binding mechanism to adhere to it. There is absolutely no reason to rush…the coal will be there. It is clearly within the purview of the regulatory agencies to postpone projects until the required regulatory framework is established. This is particularly true when there is a fixed total allowable expenditure of a resource. In this case time will not solve the problem unless you think in terms of many millennia.
The scope of the EIS should include at the least the following elements: •A full accounting of all the cumulative maximum climate and ocean impacts of all coal terminals on the Pacific coast over the full life of all of all of the terminals. •A determination of exactly how the proposed coal exports will fit within regional, national, and international carbon budgets. Consider what parts of these budgets are committed…not subject to easy reduction…and discretionary…what has not yet been committed to. What fraction of the discretionary new carbon emissions would these terminals be responsible for? Would they fit within our national budget or be allocated to a foreign country’s budget? •A determination of the cumulative long-term impact of coal dust and coal loss from all of the trains for all of the terminals on water quality and ecosystems along the routes of the trains. What are the likelihood and consequences of train derailments and the spilling of coal into waterways? Will heavy train traffic exacerbate the severe landslide problem that already exists on regional rail corridors and what will be the economic costs of the additional disruptions? How will the additional rail traffic impact boat traffic through the Ballard locks? •A determination of the impact of abundant Pacific-coast coal on the price of coal in Asia and how will this effect the long-term rate at which Asian countries do or do not reduce coal burning. Will the economic consequences have important environmental impacts? •A determination of the long-term social impacts of very large corporations moving in to small communities. Do social consequences have important environmental impacts?
The name of the proposed terminal in Longview, the Millennium Bulk Terminal, is particularly apt. The cumulative climate impacts created by the export of coal from this terminal and others will have environmental impacts that will persist for millennia .
It is imperative that the EIS fully address these long-term impacts for the State of Washington, for the nation, and for the globe and to carefully consider how these projects will fit within global, national, and regional carbon budgets for new sources of fossil carbon. Much of what we burn today will be very hard to reduce so we must first try to avoid new sources of fossil carbon.
It is not easy to think at such long time scales and to consider global impacts. But it is in the interests of the people of the State of Washington and of the United States to carefully and fully consider all of the large-scale and long-term cumulative impacts of creating a massive new conduit for the extraction and burning of fossil carbon.
Think globally. Think millennially. Act locally. Act now. Ron Lindsay 7548 Mary Ave NW, Seattle WA 98117
Thank you
Ron Lindsay 7548 Mary Ave NW Seattle, WA 98117