Submission Number: MBTL-EIS-0002195
Received: 11/17/2013 8:47:44 PM
Commenter: Sandy Robson
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
NEPA analysis should and must consider air pollution, water pollution, and noise pollution (from the very loud screeching metal of the ultra-heavy coal trains) impacts that occur from the transporting of PRB coal from the coal mines to the proposed coal terminal at Longview, and the burning of coal overseas where the coal is to be exported from Millennium Bulk Terminal. Transporting impacts that occur starting from where the Powder River Basin Coal is loaded onto trains in open top coal cars, following along the path of those coal trains through the cities and communities along the railways all the way to the Millennium Bulk Terminal in Longview. This includes the poolution from huge Capesize and Panamax vessels that will be used to ship the coal overseas. The burning of that exported coal overseas will result in sulfur, mercury, and other chemicals released from burning that exported Powder River Basin coal. Some people try and arguse that the because PRB (Western) sub-Bituminous coal has less sulfur than other coal it is considered "better" for the environment and people's health. What those people who argue that do not realize is that while Sub-bituminous Powder River Basin (Western) coal may have less sulfur, it also has fewer btu's of energy, or a lower "heat rate." Wyoming coal has, on average, 8600 btu's of energy per pound. Bituminous (Eastern) coal has heat rates of well over 12,000 Btu's per pound. The result is that power plants need to burn about 50 percent more of the lower btu Sub-bituminous coal to match the power output from higher btu Bituminous coal. So burning a higher amount of lower sulfur coal is not really any cleaner than burning a lesser amount of higher sulfur coal to generate the same needed amount of power.
Also, The Surface Transportation Board in their 2011 decision regarding the tariff that BNSF wanted to charge coal companies stated that coal dust is a pernicious ballast foulant. The link to that decision is: http://www.stb.dot.gov/decisions/readingroom.nsf/WebDecisionID/40436?OpenDocument
The STB said:
"Based on its own studies, however, USDOT concluded that “[c]oal dust is a particularly harmful ballast contaminant that requires frequent remedial action.”
The STB also stated, "Moreover, to the extent that coal dust poses a risk of harm to the environment, containment is the only way to protect the environment and communities along the right of way. Maintenance only addresses the harm to the ballast and does nothing to address the harms to neighboring streams, people, and communities. Furthermore, some coal dust removed in the rail bed maintenance process may also find its way back into the environment, either nearby or at disposal sites."
So, coal dust is a known problem and needs to be studied carefully and thoroughly starting from the rail lines used to transport it from the PRB all the way to the proposed Millennium Bulk Terminal. The potential coal dust at the terminal site also needs to be studied carefully.
What is really needed before any proposed coal terminal is permitted is that we need a regulating authority like the STB or other that will initiate rules and regulations about transporting coal via rail because they confirmed that coal dust is harmful to the environment and communities along the railways yet they have left the public unprotected. This is not fair to the public who have a level of expectation that authorities are watching over things like this, when in fact, all the STB has done is acknowledge the problem/s and not taken action to remedy those. They left that up to the railroads and coal companies to try and work that out. Meanwhile the public has no recourse. I don't think any coal should be traveling the rails from PRB to Pac NW coal terminals until regulations are set up to protect us, if it is even possible to protect us from all the coal dust escaping rail cars.
Please carefully study and consider these issues I've raised.
Birch Bay, WA