Submission Number: MBTL-EIS-0002141 

Received: 11/17/2013 1:13:46 AM
Commenter: Sophie Zhang
State: New Jersey

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
Dear Washington Department of Ecology, If built, the Millennium Bulk Terminal site in Longview, WA will enable the export of 25-44 million metric tons of coal to customers in Asia. Debris from coal dust would have a deleterious impact on the local environment and public health; increased coal use would significantly worsen the international picture for climate change, with disastrous impacts for the U.S. and the rest of the world. However, the above points have likely been made numerous points by other commentators, and as such, attempting to elaborate an argument based around those points is unlikely to be convincing to the reader. Instead, let me focus on two less apparent points regarding the benefits and costs of this project. With regard to the costs, much airborne pollution from East Asia (including China) is carried back across the Pacific Ocean over the U.S. West Coast. As such, any environmental study regarding the result of this terminal must inevitably consider the environmental impact from increased coal consumption in East Asia. With regard to the benefits, supporters generally cite claimed job and trade economic benefits, due to the common belief that demand for coal in East Asia will continue to rapidly grow thanks to increased Chinese demand. For instance, in 2013, China consumed slightly more coal than the rest of the world combined. Moreover, Chinese growth in coal demand represent essentially all of the increased world coal demand - neglecting China, world coal demand would have *decreased* by 0.6% this year (these numbers come from the 2013 BP Statistical Review of World Energy.) The conventional wisdom is that this rapid and unprecedented growth in Chinese demand for coal is required to continue its economic growth, and it is this belief which likely impelled the proposal for the construction of this terminal, back in 2010. However, much has happened in the world situation since 2010. A rapidly changing domestic situation in China has caused a massive governmental effort to shift away from coal, due in particular to public furor over the unprecedented levels of pollution and a desire on the part of the ruling Communist Party to avoid further social discontent. This policy shift includes a massive move towards natural gas, including pipeline imports from Russia, Myanmar, and Turkmenistan, domestic expansion of deep-water gas fields and shale gas exploitation, and increased imports of liquefied natural gas. This shift is coupled with a rapid expansion of nuclear energy, with ~30 new reactors already under construction (compared to 17 in operation, with an intended capacity of 200 GW by 2030) and renewable energies. Finally, the Chinese government is currently testing carbon markets in preparation for either a carbon cap+trade plan or an emission tax, either of which would severely curb coal demand in the country. In short, it now appears that the premise behind this project - increasing Chinese coal demand, which can be fulfilled through U.S. exports - is no longer true. In fact, it's quite possible that even if the plan is accepted and the terminal built, the terminal will never export the full planned capacity thanks to cratering Chinese demand for coal, and as such, will never deliver on the job and trade benefits it claims. As a result, the construction of this terminal is neither economically nor environmentally sensible, and I would recommend its cancellation as a result. Millennium may find it useful to instead consider the construction of a LNG (liquefied natural gas) export terminal, to assist in exporting cheap US natural gas from the shale gas revolution to feed increasing global demand. Natural gas is also far more environmentally responsible than coal (being considerably less polluting and taxing of water resources than coal or oil), and as such, will likely remain a crucial part of a world transition economy for another few decades. Thank you for the time, Sophie Zhang