Submission Number: MBTL-EIS-0003133 

Received: 11/15/2013 8:05:00 PM
Commenter: John Stuhlmiller
Organization: Washington Farm Bureau

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 Sent:Friday, November 15, 2013 8:05 PM Subject:Comments on Cowlitz County EIS

I am submitting these comments on behalf of the nearly 42,000 member families of the Washington Farm Bureau. The goal of my members is to provide the food, feed, fiber and fuel that our state, nation and the world need. That means every aspect of the production, distribution, and sale of our products matters.

Washington State is a trade leader. As the second largest export industry in Washington, to the tune of $13 Billion per year, we in the agricultural community have a significant stake in any debate that impacts the future of trade in the Northwest. Truly our transportation infrastructure is literally the lifeblood of our industry.

It is however important for our membership to understand if the growth of bulk exports in Washington would be a cost or benefit to the agriculture community. That's the question we commissioned Dr. Steven Globerman of Western Washington University to answer. His conclusions showed that:

1. Coal shipments are likely to lower costs to other shippers, by improving the economics of infrastructure investment and operation in Washington. 2. More efficient import and export capabilities generate economic benefits for terminal customers, including agriculture. Those "upstream" benefits have not previously been quantified. 3. Existing economic studies likely underestimate the economic benefits from the terminals, and understate how broadly those economic benefits may be dispersed. In short, all Washington exporters stand to benefit from new investments that make Washington a more reliable, efficient, and competitive gateway for global trade. Dr. Globerman's work demonstrated what we believed to be true, shoring up our existing infrastructure and expanding the export capacity in our state will indeed cause all boats to rise.

Recent reports by the Portland Business Alliance and Washington Research Council validated our research, demonstrating that increased commodity exports provides economic growth for all trade related industries, particularly agriculture.

Opponents of the proposed terminals have called for a change in how Washington evaluates export and infrastructure projects, and even for controls on what products we export. We do not support those positions. To be the successful engine in our state economy, agriculture needs a fair, predictable, and reasonable review process.

As we debate the terminals, it's important that we not overlook the competitive advantage expansion of exports brings to domestic industries, like agriculture, and the upstream value that advantage creates across our economy. Further, we must rely on the current system of environmental regulations developed over the years that provides stringent oversight of development and operation of such facilities. There is no demonstrated lack in the environmental protection web needing to be addressed. We strongly urge the Department to stick to the law and rapidly complete the environmental review to allow this much needed export expansion to occur.

Following are some more specific comments on the impacts of this project. Coal transport could lower shipping costs and boost infrastructure investment in Washington While there are a variety of reasons to back the Millennium Bulk Terminals proposal, I would like to focus on how the company's infrastructure investments will spur other companies to invest as well, helping boost Washington's export/import capacity. The Washington State Farm Bureau published a study in June finding that Millennium's coal exports will have a beneficial impact on Washington's exporters and its economy as a whole. It focused on how the company's investments will create "economies of scale" in the state's infrastructure that will reduce the marginal cost of exporting and importing goods of all kinds. Big infrastructure projects usually require a critical mass of financing before they can move forward. This is exactly what Millennium provides - a boost of capital that will catalyze a series of investments by other market players and local governments. The Washington Farm Bureau study concludes: "infrastructure investments that increase the transportation capacity serving adjacent (to the coal terminal) facilities are more likely to be made given the investment in the coal terminal than absent that investment." This is just one of the many "direct, indirect, induced and catalytic" economic benefits that Millennium's terminal will bring to Longview and Washington, according to the study. We hope you will consider these benefits during the scoping process. More efficient import and export capabilities generate economic benefits for many terminal customers, including agriculture The Washington State Farm Bureau published a study in June of 2013 focused specifically on the "upstream" economic benefits resulting from coal exports. The study concludes that these exports will have a variety of "direct, indirect, induced and catalytic" benefits for the state of Washington, and agricultural exporters in particular. These benefits can be achieved because companies like Millennium Bulk Terminals will invest in rail lines and port infrastructure that will have cross-purposes for agricultural products. The more rail lines, bridges, tarmac, commodity elevators and conveyor belts, the lower the marginal cost of exporting or importing a variety of bulk commodities, whether it's coal, wheat or other products. At a time of rising competition from other ports along the west and east coasts, it is critical that Washington embraces investments that will improve the state's export/import capacity. Please consider these benefits during your evaluation of the Millennium project. The Portland Business Alliance found that commodity exports account for more than half of all export activity in regional ports, and support substantial employment across the region. • In addition to generating significant employment in the shipping and rail industries, commodity exports provide substantial economic benefit for the entire region. One facility in Oregon - the Columbia Grain terminal supports over 5,000 wheat, corn, and soybean producers. (Source: Portland Business Alliance, "Today More than Ever: Oregon and Portland/Vancouver Depend on International Trade and Investment," page 28) • "Bulk commodity trade accounts for perhaps half of the direct jobs linked to port activity." (Source: Portland Business Alliance, "Today More than Ever: Oregon and Portland/Vancouver Depend on International Trade and Investment," page 29)

The Washington Research Council issued research showing a significant investment gap in the region that must be filled in order to keep Washington port's competitive in the global trade market. • "Our state's ability to maintain its nation leading position as a hub for domestic and international trade depends on speedy, safe, and reliable transportation connections." Large, private investments, like those provided by coal exports, will help close this investment gap through investments in transportation infrastructure. (Source: Washington Research Council, "Trade-Dependent Washington Relies on Rails," page 4) • "Continued investment in and by the major railroads is vital for the state's future. The competitiveness of the state's ports will be heavily determined by the rail connections and service they rely on, and industrial sites around the state need reliable service." (Source: Washington Research Council, "Washington Cargo Rides the Rails," page 1) • Rail is critical to our economic well-being; jobs and local economies rely on the health of rail transportation and growing our trade and export industry. Some rail lines are running under capacity; the rail line from Spokane to Pasco "currently has a capacity of 60 trains per day and operates at fewer than 50 trains per day." (Source: Washington Research Council, "Washington Cargo Rides the Rails," page 3) • "In 2011, $77.1 billion worth of goods were exported through Washington's seaports. Associated activity directly generated 35,000 jobs." (Source: Washington Research Council, "Export Activity Boosts Washington's Economy," page 1) • Washington ports competition from British Columbia and the Panama Canal completion, which could divert as much as 20-35% of west coast goods exported to the east and Gulf coasts. Getting ahead of international competition will ensure we have the correct components for growth in our region for future generations. (Source: Washington Research Council, "Export Activity Boosts Washington's Economy," page 2)

Our own research has found that three currently proposed multi-commodity terminals will provide a net benefit to other shippers and smaller exporters, like the agriculture community. • New, private investment in Washington ports make the region more competitive, by lowering costs for all local exporters who rely on trade infrastructure. (Source: Washington Farm Bureau, "Coal Exports from the Pacific Northwest and the Economic Growth of the Northwest Economy," page 3) • "Existing studies identifying the economic benefits of the proposed coal terminals arguably underestimate those benefits, perhaps significantly, and also understate how broadly those economic benefits might be dispersed throughout the regional and national economies." (Source: Washington Farm Bureau, "Coal Exports from the Pacific Northwest and the Economic Growth of the Northwest Economy," page 21) Sincerely,

John Stuhlmiller Chief Executive Officer Washington Farm Bureau

John Stuhlmiller