Submission Number: MBTL-EIS-0002534 

Received: 11/17/2013 12:00:00 AM
Commenter: Phillip Holder

Agency: Cowlitz County, the Washington Department of Ecology, and the U.S. Army Corps of Engineers
Initiative: Millennium Bulk-Terminals Longview EIS
MBTL-EIS-0002534-59305.txt Size = 6 KB
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Submission Text
From: Phillip Holder []
Sent: Sunday, November 17, 2013 4:19 PM
Subject: MBTL purpose and need; the "why" is missing or inadequate

The JARPA form submitted by MBTL on or about 2/22/12 responds to the form’s requirements
for a description of the project, on pages 6 et seq. The description of the project goes on for
several pages, until item 6a. is reached. Item 6a. requires a statement of purpose and need:
“Describe the purpose of the project and why you want or need to perform it.”

Before considering MBTL’s explanation of need and purpose, the nature of the purpose and need
statement (or “project objectives”) merits examination. Logically, the underlying purpose or
objective of any project is not to start and finish the project. Because of public impacts and often
public funding, the purpose or objective (the "why") should be to address an existing or
anticipated problem. Stating the proposed solution (the "what") as the purpose would be circular
and without substance. Yet this is exactly what the applicant’s JARPA does. The totality of
MBTL’s explanation of purpose and need in the JARPA is:

The purpose of the project is to establish a Coal Export terminal capable of handling up
to 44 MMTPA with existing and efficient rail access and sufficient berthing area for
ocean-going ships transloading material from an American Pacific Coast port for export
to Asia. While achieving this purpose, MBTL would reuse and transform an existing
industrial or “brownfields” site.

The JARPA is mysteriously denoted as “no longer active” in the document library of Like many of the Nixon administration’s
declarations of previous statements as “no longer operative”, the “no longer active” label seems
to walk back the applicant’s assertions regarding purpose and need. But it is a very short walk.
The explanation of purpose and need in the JARPA is nothing more than an even briefer
description of the project. It fails utterly to advance any recognizable purpose for the project
other than to begin and complete the project, using an existing site. Nowhere in the two sentence
explanation of need and purpose does MBTL shed any light on why this applicant wants or
needs to perform the many aspects of this major infrastructure development, or why a project of
this massive scale solves some existing or incipient problem, other than that the project has not
yet been built. Perhaps it is fair to say that the answer to 6a. is “no longer active”, for some
reason. But it showed no signs of active life even when first filed.

MBTL’s “updated project description” in a letter dated August 5, 2013, takes another pro forma
swipe at the purpose and need requirement, denoting the plan’s “purpose” as:

The proposal’s objectives are to: (1) make use of existing rail infrastructure (freight
corridors) and an efficient, direct shipping route to Asia; and (2) reuse and develop an
existing industrial terminal into an American Pacific Coast export terminal in Cowlitz
County capable of exporting up to 44 million metric tonnes of coal annually to meet
international and domestic demand.

So goes the totality of MBTL’s new and even more cryptic explanation of purpose and need.
Aside from repeating how various resources would be used and aspiring to an efficient shipping
route to Asia for the project, the explanation appears to rest completely on the concept that the
sum purpose and need for the project consists of meeting “international and domestic
demand.” If the problem to be solved includes the prudent reuse of an existing industrial site,
why is that not advanced as a purpose? Failure to identify this as a purpose cuts off any
discussion or consideration of alternatives that might equally or even better address such a

Then there is the possible but unidentified problem that might be solved just by the export of
coal. Is the problem that earth’s atmosphere needs more carbon added to it to accelerate climate
change, that ships await cargo and must be filled, that federal and state policy on greenhouse
gasses must be undermined, that shareholder concern is up and stock values are down? The
applicant gives not a clue.

And the export of coal as a solution to any legitimate problem in present circumstances is at best
questionable. Take “domestic demand” first. Exporting coal to meet domestic demand (via “an
efficient, direct shipping route to Asia”) is nonsensical without some epiphany triggered by a
cogent explanation. The cogent explanation is missing, or perhaps it is merely “no longer
active.” There is no demonstrable demand for coal in the western U.S. that would merit shipping
over water. See e.g.,

Second, the slim reed of “meeting international demand” neglects to show why this applicant
wants or needs to meet the purported international demand. And “international demand” for
U.S. coal is anything but a given, anything but the constant and established reality suggested by
the applicant. International demand for U.S. coal has fluctuated wildly over the past two years,
and is currently below realistic profitability. See,

Any applicant for a major infrastructure project of this magnitude should not be allowed to
proceed on the basis of a JARPA, or for that matter a three page letter, that fails even to make
prima facie purpose and need (or “project objectives”) assertions that, if borne out, would satisfy
SEPA and NEPA. Pro forma “happy talk” is not sufficient.

The applicant addresses purpose and need with a tautological feint (indeed did so twice), and by
craft avoids identifying any legitimate or public problem that the project might solve or address.
This dampens any analysis that might examine alternatives to the MBTL, so a “no action”
alternative is fully appropriate for this EIS. I recommend the “no action” alternative.
Phillip Holder
Mount Vernon, WA 98274