Submission Number: MBTL-EIS-0002645 

Received: 11/9/2013 12:18:00 AM
Commenter: Bob Eugene

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
From:Bob Eugene <> Sent:Saturday, November 09, 2013 12:18 AM Subject:Millennium Bulk Terminals - Longview Comments

To: U.S. Army Corps of Engineers, the Washington State Department of Ecology, & Cowlitz County:

I strongly oppose the construction of a coal export terminal at Longview, WA without preparation of a Programmatic Environmental Impact Statement (PEIS). A PEIS is a comprehensive review of projects with impacts that are significantly interrelated, either programmatically, regionally or environmentally. Please include the following in the environmental impact study and statement.

This proposed terminal is no more than a link between mines in Montana and Wyoming, rail transportation systems, a series of ports, ship transport across the Pacific Ocean to a final destination for thermal transfer into another type of energy.

There are adverse natural environment impacts including deforestation of the lands near the mines, geological changes and similar impacts will result from construction of additional rail lines.

There are adverse impacts to the air, through both diesel and other fuel emissions and coal dust escape throughout the path from the mines through the entire paths to the final destination for combustion and the product of combustion into the atmosphere and returning to the U.S. and other countries throughout the globe impacting the local environment and the climate. Consideration of adverse impacts of both full and empty rail cars and diesel locomotives should be considered because other coal train corridors experience adverse impacts in both directions of rail car travel.

There will be water degradation not only during mining operations and rail construction, but also during transport to, through and beyond the proposed terminal. Water impacts will likely be the result of surface water runoff modifications due to re-contouring and deforestation causing further erosion, likely damage to streams and rivers, Accidents along the rail lines and in the shipping lanes will occasionally result in ecological damage similar in nature to the Capesize ship carrying coal from Richards Bay Coal Terminal to China's Fangcheng port has run aground and partially sunk off South Africa's west coast while exiting the port due to adverse weather conditions and rough seas causing extensive ecological damage.

There will be air emissions of coal dust and diesel fuel along the entire rail line causing chronic problems such as a resident of Rosedale, B.C. is concerned about the "ludicrous" amount of dust coming off coal trains recently, and has caught the pollution on video.

The habitat for and numbers or diversity of species of plants, fish, or other wildlife will be adversely impacted by the mine development and operation, the rail construction and operation and the terminal construction and operation. The adverse impacts will likely be a result of the deforestation, noise of operations, transportation traffic and other impacts.

Regarding energy, coal is among the dirtiest and least efficient for conversion to electric power. Nearly every country except the U.S. is moving from coal and other fossil fuels to cleaner forms of energy such as wind, photovoltaic and wave energy sources. Even China, the nation with the greatest use of thermal coal has committed to significantly reducing its use of coal due to environmental concerns. This year, August 20 was Earth Overshoot Day. Humanity has exhausted nature's budget for the year and is now operating in overdraft, according to data from Global Footprint Network, an international sustainability think tank with offices in California, Europe and Japan. Earth Overshoot Day is the approximate date humanity's annual demand on nature exceeds what Earth can renew in a year. There are better alternatives to supply energy to users than coal. The study needs to consider the cumulative impact of supplying a demand that exceeds what Earth can renew in a year, and consider alternatives to thermal coal transport to meet the earth's annual demand for energy.

Regarding the built environment, the proposed terminal will likely be noisy and would need to be well buffered; the increased train traffic and shipping traffic to and from the terminal will disrupt other surface traffic, and potentially impacting emergency response. Coal, under the right conditions can self ignite, and large quantities of such fuel will be very difficult to extinguish, likely resulting in significant air pollution, and result in injury or death to employees and emergency responders.

The terminal will provide blight on the ocean shores, whereas an alternative use for this property could provide a more compatible use and provide significantly greater economic benefit to the region with significant adverse environmental impacts.

The Department of Transportation has indicated that there would be no adverse effect to passenger train service, but with the number an length of coal trains proposed, and the residual coal dust that will be left along the tracks with each train, even those passengers traveling will experience air quality degradation even if there are no delays in their travel schedules.

An alternative that should be seriously considered is the "no action" alternative. The terminal should not be built because of the significant adverse impacts that will result if this terminal facilitated the degradation of the global environment.

If the "no action" alternative is not chosen, the following mitigation measures should be seriously considered:

1. Limit coal transported into the state and into the terminal be limited to being shipped within vacuum sealed containers to limit coal dust from escaping along the transportation route and within the terminal.

2. Limit the storage volume of coal within or external to containers to limit the potential of auto-ignition of coal into an inferno that exceeds the readily available fire extinguishing systems.

3. Require the terminal to have a plan acceptable to the local fire department/district, department of ecology, state fire marshal and other entities as applicable to mitigate excess product from being delivered to the terminal when offshore markets are not receiving coal. This plan should consider that other countries may shift from coal-fired thermal energy plants, vessels may not be available to transport coal from the terminal on other circumstances that a reasonable person could anticipate.

4. Require a surcharge of not less than $10.00 per ton of coal received into the terminal to pay for necessary transportation and infrastructure improvements and maintenance to avoid placing such burdens on taxpayers that are not benefiting from the terminal, but being adversely impacted. Any excess funds beyond those necessary for transportation and infrastructure improvements shall be used for environmentally friendly energy production such as wind, solar, or wave energy and clean energy storage such as high capacity battery storage. Additionally, no tax incentive should be paid for the benefit of the owners for the mining or transportation of the coal to or through the terminal.

5. All rail crossings should be required to be grade separated from surface travel to avoid long delays of normal travel and emergency vehicle travel. Taxpayers that do not benefit from the terminal should not be inconvenienced in their daily lives for the benefit of the terminal owners/operators. The grade separated crossings should be a condition of approval and should be in place prior to the opening of the terminal.

Thank you for the consideration of my concerns. Please keep me informed of any all activity relating to environmental review and possible permitting of this project and associated actions.

Bob Eugene 121 Woodard Rd Newport, WA 99156

509 447 5700