Submission Number: MBTL-EIS-0002832 

Received: 11/17/2013 12:22:00 PM
Commenter: Alex Ramel
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:Alex Ramel <alexwramel@gmail.com> Sent:Sunday, November 17, 2013 12:22 PM To:comments@millenniumbulkeiswa.gov Subject:Scoping Comments from Alex Ramel

Please find below my comments regarding the Millennium Bulk Terminal Longview project EIS scoping. Please let me know if you have any questions or require any additional information. Alex Ramel 2308 Woburn St. Bellingham WA 98229 360-305-5079 alexwramel@gmail.com

1.It is crucial that the impact on greenhouse gas emissions from the burning of the coal transmitted via this proposed terminal be considered in the EIS. Although these emissions will occur off site, they are none-the-less significant to the EIS for several key reasons: a.Without this project, these emissions would not occur. The coal market in the United States has been declining and without access to a new market, it is likely that for the foreseeable future the coal in question would remain in the ground unburned. b.The magnitude of the impact is enormous. Based on an assumption of 44 million metric tons of coal, and using the Department of Energy's value of 2.86 tons of CO2 per ton of coal (http://www.eia.gov/coal/production/quarterly/co2_article/co2.html), this project will result in 125.8 million metric tons of CO2 emissions per year. For comparison, the entire state of Washington's GHG emissions were 101.1 million metric tons from all sources in 2008 (https://fortress.wa.gov/ecy/publications/publications/1002046.pdf). c.Offsetting this impact would be a correspondingly enormous task. For example, the State of California has recently established a market mechanism for reducing greenhouse gas emissions. At auction last month, 2016 emissions allowances were sold for $11.10 per metric ton. (http://www.platts.com/latest-news/electric- power/washington/california-auctions-vintage-2013-ghg-allowances-21453971). If this project were to offset its greenhouse gas footprint, the offsets purchased at this price would cost $1,396,824,000 per year (actually, it would be substantially more than this since the entry of these emissions into the market would drive up the price significantly). d.Unfortunately, an alternative opportunity to address these carbon emissions does not exist. There are no binding regulatory standards in place through international treaty. These emissions will impact Americans and Washingtonians, but outside of this EIS, we will not have another opportunity to consider those impacts.

2.The EIS should properly account for the real possibility that the terminal will prove to be economically defunct, and should therefore disclose, for every impact analyzed in the EIS, whether that impact will persist should the proposed terminal cease or curtail operations at some point in the future. This is not a hypothetical concern, a coal export facility was attempted in California in the 1990's and closed only 6 years after opening due to unfavorable economics (http://daily.sightline.org/2011/09/12/gambling-on-coal-and-losing/ ).

Present economic operation of the terminal and the export of coal depends upon coal mining companies securing leases of federal public lands which are below market rates. Recently several members of the US Senate have called for an investigation of these below market rates (http://www.reuters.com/article/2013/01/04/us-usa-coal-investigate- idUSBRE9030GT20130104). A change in policy could lead to an increase in future lease prices or royalty payments, which could increase the cost of this project's coal enough in Asian markets to dramatically reduce the proponent's capacity to find customers for their product. This is just one example of the many possible scenarios in which market conditions could change in a way that is unfavorable to the proponents.

It is quite possible that the terminal will be constructed, but would not operate at capacity for more than a handful of years. This terminal could end up defunct and derelict much like the Long Beach terminal in California. The EIS needs to carefully account for this contingency. The proposal is being sold to the community as a job creation project and it is important that if these jobs are to dissipate that the project proponent be required to undo the damage that was done in exchange for those jobs.

a.For every significant impact identified in the EIS, determine whether the impact will persist despite non-operation of the facility. For example, many impacts to aquatic ecosystems in the Columbia River will continue whether or not the terminal is in operation. Every impact in the EIS should be evaluated with this contingency in mind.

b.In all cases where non-operation of the facility will none-the-less result in an ongoing impact, identify a strategy to provide appropriate mitigation in the contingency that the project is not operating as anticipated and providing the promised jobs. Such contingencies should include appropriate engineering and estimated costs to restore the site to its original state. Given that these circumstances are likely to arise in a situation in which the project proponent is experiencing financial difficulty, it is important that the plan be in place and agreed to before construction commences and that bonding or other mechanisms are in place in order to ensure that cleanup will happen despite possible bad fortune for the proponent. All necessary steps should be taken to ensure that the public and the community are not saddled with environmental impacts that no longer have any corresponding job creation benefits.