Submission Number: MBTL-EIS-0002802 

Received: 11/19/2013 1:26:00 AM
Commenter: Luvimae Omana
Organization: 
State: 

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:Luvimae Omana <lomana@lawschool.gonzaga.edu> Sent:Tuesday, November 19, 2013 1:07 AM To:comments@millenniumbulkeiswa.gov Subject:Docket number 2013-19738: Comment on scope of EIS for Millennium Bulk Terminals Longview LLC Coal Export Terminal

Dear U.S. Army Corps of Engineers, WA Department of Ecology, and Cowlitz County Commission,

"The Northwest [has a] long[standing] and historic commitment to expanding trade, which today supports four in every 10 jobs in Washington state," said Lauri Hennessey, a spokeswoman from The Alliance for Northwest Jobs and Exports. This is the platform pro-coal train supporters often cite. However, any large scale decision, such as creating export terminals in Whatcom County to export coal to China, must undergo a cost-benefit analysis to determine whether any such decision will improve society. In this case, I believe the cost of transporting coal from the Powder River Basin to export terminals in Western Washington outweigh the benefits it may provide.

The US and Washington have set goals to reduce climate change by promoting alternatives to projects that generate greenhouse gas emissions and ways to mitigate emissions that can't be avoided. (EPA has made formal findings that greenhouse gases endanger public health and welfare, 74 Fed. Reg. 66496. It has also issued the "tailoring rule" to regulate emissions of greenhouse gases from stationary sources, 75 Fed. Reg. 31514; See RCW 70.235.070(1)(a) (Listing greenhouse gas reduction standards). Additionally, Washington has passed executive orders to promote the reduction of greenhouse gases and increase availability of energy alternatives. Washington citizens passed 1-937, which mandates 15% of all electricity energy to come from renewable energy by 2020.

Under NEPA, reasonably foreseeable future actions need to be considered even if they are not specific proposals. N. Plains Res. Council v. Surface Transp. Bd., 668 F.3d 1067, 1079 (9th Cir. 2011). Further, NEPA requires climate-related impacts, including indirectly related impacts to the project under review, be reviewed. Id. Transporting coal to the proposed Cherry Point terminal implicates a significant amount of environmental impacts. First, mining coal contaminates the air, surface and ground water, and publicly owned lands. Transporting coal long distances across various states and considering the large volumes of materials over long distances consumes far more fossil fuel. Second, each train car can lose hundreds to thousands of pounds of coal and coal dust during transportation. Where coal trains typically consist of 120 cars, thus around 3,600 pounds of coal and coal dust can be lost on one trip. See Exh. 112, Hearing Transcript, July 29, 2010, Arkansas Electric Cooperative Association - Petition for Declaratory Order, Surface Transportation Board, Docket No. FD 35305, at 42: 5-13. EPA must also consider other implications, such as air emissions, when transporting large volumes of coal. Each trip from the Powder Basin to China uses about 500 tons of bunker fuel, which generates a significant amount of CO2 emissions, diesel particulates that are highly dangerous to human health.

After taking into consideration all of the factors and balancing the interest between creating jobs and environmental concerns, it is clear Spokane and Washington state's interests are better served without coal trains running through the state. Further, job creation will arise from different sources or in a different industry. When innovative and clean solutions become readily available in the market, traditional and dirty technology such as coal fall to the wayside. To close, the Environmental Impact Statement must take into consideration that the proposed plan must comply with regulations set forth by the EPA and WA statutes and future foreseeable actions that are consequences of the proposed action.

Sincerely, Luvimae Omana

Luvimae Omana 721 N. Cinncinnati Street Spokane, CA 99202