Submission Number: MBTL-EIS-0002316 

Received: 11/18/2013 8:57:01 PM
Commenter: Stephanie Buffum
Organization: Friends of the San Juans
State: Washington

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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Submission Text
III. CUMULATIVE IMPACTS OF VESSEL TRAFFIC The total number of cargo and tanker vessels calling at Columbia River terminals in 2012 was about 1428 . Considering the two proposed coal export terminals, Millennium Bulk Terminal and Port Westward Coyote Island Terminal, coupled with Ambre’s Pacific Trans loading Barge Dock, the number of vessels navigating the Columbia River could increase by as much as 50%. The number and size of ships visiting the existing and proposed terminals and the amounts of hazardous cargo or fuel within those ships elevates the risk of shipping accidents and fuel spills in the Columbia River, the Columbia River Bar, or surrounding ocean waters. Although the annual number of oil tanker spills fell about three-fold world-wide between 1992 and 2011, the number of fuel spills for allisions, collisions, and groundings of tankers and bulk cargo carriers in restricted and inland waters did not decrease during this period. These data indicate that improvements in the shipping industry, the efforts of the International Maritime Organization, and national governments have not decreased the number of accidents in inland and restricted waters. As an inland waterway, the Columbia River’s significant spill risk could be even greater than the world-wide average. In contrast to the reduction in tanker fuel spills (likely due to double-hulls and other structural improvements in tanker design); world-wide bunker fuel spills did not decrease between 1992 and 2011. Bunker fuel is the generic term for fuel used by ship engines. It is heavier and more polluting than other fuels. The bunker fuel capacity of most large bulk carriers can be as much as 1.2 million gallons. These are single hull vessels with double bottoms that experience a historically higher mechanical failure and accident rates than other vessels. Combine these characteristics with the fact that most are operated by foreign crews, and misunderstandings or miscommunications, navigational errors (despite the presence of a US Pilot) will additionally contribute to the risk level. Bulk carriers travel without tug escorts, and require a large amount of room to maneuver. In an emergency, they require up to 1¼ miles to stop with power, and up to 7 miles without. In addition, these ships have large areas above the water that act as a sail. At low speed, this “sail area” makes them difficult to maneuver. An un-powered ship is even more subject to wind and currents, and will be essentially out-of-control without power or tug assistance. The absence of tug assistance, inadequate ship maintenance and crew training along with severe weather all increase the risk of a fuel spill. In an emergency, tug assistance can be undependable because it is based on the vessel of opportunity concept. This means that any tug that happens to be in the area may be called upon to provide assistance to a stricken vessel. However, a randomly available tug may not have the power, the proper equipment, or crew training necessary to render effective assistance to a large vessel in distress. The bar at the entrance to the Columbia River is a physical challenge to any mariner and seagoing vessel. The following is from “Running the Bar” in the February, 2009 Smithsonian Magazine: ‘Each of the 16 bar pilots has the authority to close the bar when conditions are too dangerous.’ Still, "When we shut down the bar for two days, trains are backed up all the way into the Midwest. And just like a traffic jam on the freeway, once you clear the wreck, it takes a long time for it to smooth out again." The impediment of the Columbia Bar has the potential to cause substantial delays in shipping schedules, particularly during stormy conditions. Shutting down “the bar” for several days in bad weather could result in coal trains accumulating all along the rail transport corridor, all the way back to the mines. See additional Comments in attached letter