Submission Number: MBTL-EIS-0002009
Received: 11/13/2013 10:22:08 AM
Commenter: Beth Kaeding
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
I am submitting the following scoping comments to the U.S. Army Corps of Engineers (Corps), Washington Department of Ecology, and Cowlitz County in response to the August 16, 2013, Notice of Intent (NOI) to prepare an environmental impact statement (EIS) on the application from Ambre Energy and Arch Coal to build Millennium Bulk Terminals – Longview, LLC (MBTL). These comments are submitted in an effort to aid the Co-Lead Agencies in identifying issues that I believe should be addressed in the EIS. Please ensure that my comments are entered into the public record.
The proposed rail transport of Powder River Basin (PRB) coal from and through Montana to the West Coast will have real and significant impacts to Montanans and are a connected and cumulative result of what happens at MBLT. The EIS being prepared by the Co-Lead Agencies for the MBLT project MUST include the connected and cumulative impacts that increased coal train traffic will have and cause all the way back through Montana to the PRB coal mines in Montana and Wyoming.
As a former federal compliance officer, I completely understand the National Environmental Policy Act (NEPA). Through the Council of Environmental Quality’s NEPA implementing regulations, an agency is required to analyze any proposal in consideration of other actions that are connected (40 C.F.R. §1508.25(a)(1)) and are cumulative (40 C.F.R. §1508.7, §1508.25 (a)(2)). As I am sure your agency compliance officers know, a “connected action” is any action that is closely related to the proposal, cannot or will not proceed unless the proposal happens, or those that are interdependent parts of a larger action and depend on the larger action for their justification. “Cumulative impacts” are those “which result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.”
The MBTL facility at Longview, Washington, is only one part (albeit a major part) of an overall plan by coal and rail corporations. Based on PRB coal company projections, coal export will amount to at least 75 million tons of coal and as much as 170 million tons each year through Montana. This means that Montana will likely experience at least 30 more coal trains (15 loaded going west and 15 empty returning to the coal fields) and up to as many as 64 more coal trains each day – in addition to all the train traffic we currently experience. All outgoing coal trains from the PRB headed for Pacific Northwest ports pass through Billings, Montana. My community of Bozeman could experience 15 to 20 more trains each day on top of the 16 to 20 trains we currently experience.
The proposed MBTL facility is integrally connected to this increased coal train traffic as well as increased coal mining and increased pollution from the burning of coal. There are connected health, life/safety, economic, and social costs from this project all the way back to the PRB coal mines in Montana and Wyoming. All of these connected impacts are also cumulative.
The increased number of trains in Montana will mean more noise, a greater potential that emergency responders will be delayed in reaching residents when there is a medical emergency (or a fire or the need for police) “across the tracks,” a greater potential for vehicle collisions with trains and for pedestrian accidents, an increase in the amount of airborne pollutants (particulate matter) from diesel engines as well as from coal dust. Additionally, more trains will mean more vehicles idling at train crossings when trains are passing – and adding their exhaust (containing particulate matter and other pollutants) into the air. All of these connected and cumulative impacts must be addressed and analyzed in the EIS.
The economic impacts to all the communities along the rail lines from the MBTL facility to the PRB must be considered in the EIS. Federal law requires train engines to blow when approaching a crossing whether that crossing has guard arms that come down or not. There is a process that communities can go through to establish “Quiet Zones” in order to eliminate the sound of train horns. But, the citizens of any Montana community wanting a Quiet Zone generally will have to pay for the infrastructure upgrades required that allow trains to not blow their horns. Many towns and cities in Montana are bisected by rail lines. The cost for infrastructure upgrades, such as overpasses, underpasses, and bypasses, needed to facilitate vehicle traffic in those communities must be addressed and analyzed in the EIS.
The effects of coal export extend far beyond the West Coast export terminals and will result in system-wide impacts throughout the rail transportation system of the region extending back to southeast Montana and northeast Wyoming. Agricultural products, containerized shipments, passenger rail traffic will all be impacted by this proposed project, and those issues must be addressed and analyzed in the EIS.
Because the primary (or sole) reason for the MBTL facility as well as the other proposed West Coast coal export terminals is to ship PRB coal to Asian markets, these terminal projects will lead to a significant increase in coal mining in the PRB. Thus, increased coal mining is a connected and cumulative impact of the MBTL facility and the other proposed West Coast coal export terminals, and these impacts must be addressed and analyzed in the EIS.
The proposed Otter Creek coal mine is just one example of a connected and cumulative impact of the proposed MBTL project. If fully developed Otter Creek would become one of the largest new coal strip mines in North America. Otter Creek coal is destined for the export market. Arch Coal (the corporation that wants to open the mine and a partner in the MBTL facility) has made several representations to investors and others that the Asian export markets would be the primary market for the Otter Creek coal. This coal will be shipped, primarily to China, via the proposed new coal export terminals in the Pacific Northwest.
Not only would the proposed new Otter Creek coal strip mine fundamentally change the character and quality of life in a quiet, rural, productive agricultural region of southeastern Montana; impact wildlife, native grasslands, and cultural resources; destroy aquifers; and lessen air quality, but it would also result in the building of the Tongue River Railroad (TRR). The one and only purpose of building the TRR is to haul Otter Creek coal. This railroad would destroy additional productive agricultural lands, bisect and devalue ranches, and industrialize the region. These and other impacts from increased coal mining will be the direct result of a coal export program that the MBTL facility as well as other West Coast port expansion proposals promote.
Ambre Energy owns a 62% interest in the MBTL facility and 100% interest in the proposed Port of Morrow export terminal in Oregon. Ambre Energy currently owns a 50% interest in the Decker Mine in Montana. Cloud Peak Energy, the nation’s third largest coal producer, owns the other 50% interest in the mine, but in a recent legal agreement that is not yet final, Ambre Energy is to acquire sole ownership of the Decker Mine. In exchange, Cloud Peak Energy would receive (among other things) a guaranteed amount of export tonnage capacity at MBTL.
Earlier this year, Ambre Energy (via their subsidiary Decker Coal Company) submitted a lease modification amendment (LMA) request to the Bureau of Land Management (BLM) proposing to add another 500 acres (and nearly 41 million tons of coal) to its existing West Decker Coal Mine leases. Based on all the information reported about Ambre Energy’s market plans, it is highly probably that the coal resources contained in this lease amendment request are destined for the export market.
Consequently, because the sole purpose of the MBTL project is to facilitate the shipment of coal being transported from the PRB to its final destination in Asia – particularly China – where it will be burned for energy, the Co-Lead Agencies must give full consideration to the long-term indirect effects that this federal action will have on global climate. The burning of coal is a connected and cumulative impact of the MBTL project. Although all fossil fuels contribute to climate change, coal’s contribution is by far the most significant. The export of our nation’s coal resources to China and other Asian nations where it will be burned – often in plants where there are few, if any, air pollution controls in place – will result in significant consequences for Montanans and all Americans. The EIS must examine the connected and cumulative impacts of this proposal on climate change.
I believe that the Co-Lead Agencies must give full consideration in their EIS to the long-term direct and indirect effects that the extraction, transport, export shipment, and final combustion of PRB coal present as connected and cumulative impacts of the MBTL project. I also believe that the connected and cumulative impacts to Montana from the proposed MBTL project must be included in the EIS.
I oppose the proposed MBTL project. I believe in the NEPA process. Done openly, honestly, and with solid and factual data that is objectively analyzed, I believe the EIS will show the decision makers that the social and environmental costs of the MBTL project far outweigh any benefits of the project, except those financial benefits that a few corporations will receive.
Thank you for the opportunity to participate in this scoping process.