The first thing i want to say is there are no other alternatives and there is no mitigation possible to this project. The only answer is no project.
Now i would like to submit a statement in it's entirety (including footnotes) from the League of Women's Voters of Whatcom County to tis national organization. This statement says what i want to say in better form than i could.
Position Paper - West Coast Coal Terminals
presented by: The League of Women Voters of Bellingham/Whatcom County
The League of Women Voters of the United States (LWVUS) Statement on Climate Change is:
Global climate change threatens the integrity of the earth's climate system and there is a need to act without delay to substantially reduce greenhouse gas emissions.
To reduce the likelihood of severe damage to both human societies and natural ecosystems the League supports:
The preservation of the physical, chemical and biological integrity of the ecosystem and maximum protection of public health and the environment.
Energy goals and policies that acknowledge the United States as a responsible member of the world community through sound use of energy resources with consideration of the entire cycle of energy production and emphasis on conserving energy and using energy-efficient technologies.
In addition, the League believes that policy makers must take into account the ramifications of their decisions on the nation as a whole as well as on other nations.1
LWVUS has advocated for government action that impacts positively on the public health, particularly eliminating carbon emissions and mercury in our waters and soils.2 The League of Women Voters of Bellingham-Whatcom County in Washington finds itself at the center of a controversy with international implications for global climate change and direct environmental impacts. The goal of this paper is to encourage the national organization to take a position in opposition to development of coal terminals on the Pacific Coast, and to endorse specific actions recommended by LWVWC as it reaches out to other Leagues impacted by those terminals.
The Problem of Coal as an Energy Source
Efforts are underway nationally by environmental groups to address our nation’s reliance on coal as an energy source,3 but suddenly the focus has shifted to exports, which have increased more-or-less steadily, from 40 to 80 million short tons4 per annum since 2001.5 In the next few years, demand for sub-bituminous coal in the Pacific Rim could reach 250 million short tons per annum, up from 140 millions short tons today.6
Coal is the most carbon-intensive fuel we can use to generate energy,7 and the major contributor to CO2 emissions in the United States.8Each short ton of Powder River Basin coal burned, contributes over 2.8 short tons of CO2 to the atmosphere.9Unfortunately, as this country weans itself from coal, there is increasing demand overseas, particularly in China, which could lead to demand for up to a billion tons of coal in the future according to Peabody Energy.10 This accounts for predictions that China’s contribution to greenhouse gases from coal burning over the next 25 years will exceed that of all other industrialized countries combined.11
In addition to its contribution to greenhouse gases, coal contains toxic substances including mercury, only 35% of which is captured by pollution control devices during burning.12None is “captured” from dust released when coal is mined, transported by freight, stored out-of-doors at waterfront terminals awaiting shipment, or being loaded on ships; hence the term “fugitive” coal dust. Mercury is a serious health hazard. It damages the human heart, brain, kidneys, lungs, nervous and immune systems.13 Fetal exposure can impact neurological development and impair cognitive functioning of children.14
The U.S. as an Emerging Major Coal Exporter to the Pacific Rim
The U.S. shipped less than 18 million short tons of coal to Asia in 2010,15 and prospects for increasing exports in the future were deemed constrained because U.S. coal was more expensive than that of the largest exporter, Australia and the other exporting nations, in part because of shipping costs.16 That is changing due to China’s exploding demand for coal, coupled with numerous factors that are internationally constraining exports. Suddenly, U.S. coal is more competitive.17However, there is not enough export capacity at existing U.S. coal terminals, e.g. McDuffie Coal Terminal in Mobile, AL,18 and Lamberts Point Coal Terminal in Norfolk, VA.19Those terminals ship coal to ports in the U.S. and Europe with excess capacity going to China; but volumes are extremely limited (possibly less than 5 million short tons per annum combined). It’s much more expensive to ship from the Gulf and/or inland than from the west coast.20Not surprisingly, with the sudden surge in demand in China, there is a major push on to “move the coal,” and particularly to build coal terminals on the U.S. West Coast.
Permit applications are pending for two huge coal terminals in Washington: one proposed by Ambre Energy of Australia, and U.S. mining operator Arch Coal, in Longview, WA;21 and another proposed by Pacific International Terminals (PIT), a subsidiary of SSA Marine, a “privately-held”22 Washington-based stevedoring company, at Cherry Point, Washington, just north of Bellingham. Combined, the two terminals could ship over 100 million short tons of coal per annum to Asia.
In Cowlitz County, Washington, Arch Coal originally filed a permit application to expand the existing Millennium Bulk Logistics Longview Terminal to add the capacity to ship 5.7 million short tons of coal, but during the discovery process when environmental groups challenged the permit with a lawsuit,23 documents revealed the company planned to ship up to 60 million short tons without conducting an environmental review to determine impacts of shipping that volume of coal.24 The original application was withdrawn,25 to be re-filed reflecting intended coal shipments.
In Whatcom County, Washington, the proposed Gateway Pacific Terminal (GPT) would be built at Cherry Point, an area zoned for heavy industry on the coast of the Georgia Strait between Bellingham and the Canadian border. Cherry Point is a unique site because of its deep water which accommodates cape sized shipping vessels – (1000 ft. long and often over 200 dead weight ton capacity) – without dredging. That, combined with the relatively flat land and rail access, makes it the ideal location for a deep-water shipping terminal.26 SSA originally applied for, and received, permits from Whatcom County to build a terminal to ship 8.2 million tons of commodities listed as feed grains, petroleum coke, iron ore, sulfur, potash, and wood chips..27, 28 That volume required 140 ship calls per annum.29 Those permits apparently did not consider rail impacts on Whatcom or other communities along freight lines.
A coalition of environmental groups and the League of Women Voters of Bellingham-Whatcom County (collectively referred to as WEC) appealed the 1997 permits granted by Whatcom County, and the Washington State Departments of Ecology (ECOL) and Fish & Wildlife (WDFW) joined the appeal. At issue was failure of the Environmental Impact Statement (EIS), upon which the county relied in granting permits, to address environmental impacts to the fisheries and uplands. In 1999, the agencies and WEC appellants entered into a Settlement Agreement with PIT.30The agreement addressed environmental issues including:
Mitigating impacts on inland wetlands and on macro algae in the coastal waters in the Strait of Georgia which form the basis for the food chain in the Cherry Point region, particularly for herring;
Monitoring the dwindling Cherry Point herring population;
Ballast water exchange requirements (because of the introduction of foreign species into the coastal waters); and
Handling and treatment of sediment produced by operations and storm water runoff from stored commodities to minimize impacts on the land and water.31
SSA Marine did not begin construction on the terminal. Rather, in 2010 they initiated permit proceedings anew for a vastly expanded terminal from which the major product to be exported is up to 48 million short tons of coal.32 They formally filled a Joint Aquatic Resources Permit Application (JARPA) in February of 2011.33 In March, Peabody Energy Corporation, the largest U.S. coal producer, accounting for nearly 20% of U.S. coal production,34 announced it had entered into a contract with GPT to initially ship up to 24 million short tons of coal through the Gateway Pacific Terminal.35Environmental groups challenged permit applications filed with Whatcom County (June 10, 2011),36 claiming SSA sought to avoid full environmental review of the proposed terminal.37On June 23, 2011, Whatcom County Planning
& Development Services returned the applications as incomplete stating a new permit must be requested, and that the Shoreline Management Act – which contains stringent environmental review – would govern.38
The Gateway Pacific Terminal (GPT) and Millennium Bulk Terminal would have enormous impacts on nearby communities and waterways. At full operation, SSA projects that one train per day would arrive at GPT to deliver other commodities, but eight trains per day would deliver coal, each with 170 cars.39According to BNSF, each coal car loses about 3% of the loaded weight as fugitive coal dust along rail routes during transport from mines to power plants.40As discussed above, Millennium terminal could ship 60 million short tons of coal per year; GPT could ship 48 million short tons of coal; combined there could be trains from the Powder River Basin transporting 108 million short tons of coal per year to the coast of Washington. This could result in the release of over 3 million tons of coal dust en route from Wyoming and Montana to the west coast. For that reason, 130 Bellingham physicians have signed petitions asking elected officials to ensure that the review of potential environmental impacts of the coal terminal includes measuring the impacts on populations exposed to fugitive coal dust.41This might be difficult to measure but it will be even more difficult to predict future impacts on waterways of fugitive coal dust which finds its way there from the air, as well as runoff and leaching from the land.
Those opposing the construction of coal terminals on the west coast have taken the position that because coal’s impacts on the environment and human health are known, we need not wait ten years to 1) measure effects of mercury levels on our waterways, 2) measure the deteriorating health caused by exposure to fugitive coal dust along our nation’s rail lines, 3) measure particulates released from the burning of U.S. coal in the Pacific Rim, or 4) measure the effects of the contribution to greenhouse gases of 100 million short tons of U.S. coal burned abroad. Terminal proponents argue China will burn coal whether it originates here or from Australia or another coal producing region. That may or may not be true because opposition to coal is a growing worldwide movement. But if it were true, it would not make conscionable that which is not. Seldom can acting locally have a profound impact on matters of global scale. This is such an opportunity, which is why the League of Women Voters Bellingham-Whatcom County urges a position in opposition to the building of terminals on our western shore for the shipping of U.S. coal to the Pacific Rim.
2 http://www.lwv.org/AM/Template.cfm?Section=Clean_Air_Defense&Template=/TaggedPage/ TaggedPageDisplay.cfm&TPLID=144&ContentID=16882.
3 See, e.g., Sierra Club’s “Beyond Coal” campaign, http://www.sierraclub.org/coal/; Climate Solutions’ “Power Past Coal” campaign, http://climatesolutions.org/; Earth Justice’s “Climate and Energy” focus, http://earthjustice.org/our_work/climate_and_energy.
4 A short ton is 2,000 pounds. http://en.wikipedia.org/wiki/Short_tons.
5 U.S. Coal Supply and Demand:2010 Year in Review, U.S. Energy Information Administration, June 1, 2011,Fig. 8.http://www.eia.gov/coal/review/.
6 Gelsi, Steve, Peabody Energy to Boost Coal Exports, THE WALL STREET JOURNAL MARKET WATCH (quoting a Peabody spokesman), Mar. 1, 2011, http://www.marketwatch.com/story/peabody-hopes-to-boost-us-coal-exports-2011-03-01?rss=1.
7 Dep’t of Energy & Environmental Protection Agency.Carbon Dioxide Emissions from the Generation of Electric Power in the United States(July 2000): 1, 7, www.eia.gov/cneaf/electricity/page/co2_report/co2emiss.pdf.
8 Id. at 3, 7, 8.
9 Hong, B.D. & E.R. Slatick, Carbon Dioxide Emission Factors for Coal, Energy Information Administration, Quarterly Coal Report, Jan.-Apr. 1994, DOE/EIA-0121(94/Q1) (Washington, DC, Aug. 1994): 1-8, http://www.eia.gov/cneaf/coal/quarterly/co2_article/co2.html.
10 Lobsenz, George, Peabody: China, India Leading Coal “Supercycle,” Coal Power, Dec. 1, 2010. http://www.coalpowermag.com/environmental/297.html.
11 Bradsher, Keith & David Barboza, The Energy Challenge: Pollution from Chinese Coal Casts a Global Shadow, New York Times, June 11, 2006.
12 Mercury: Basic Information. http://www.epa.gov/mercury/about.htm.;Mercury in Coal, United States Geological Survey (USGS), Eastern Energy Resources Science Center (EERSC), http://energy.er.usgs.gov/health_environment/mercury/mercury_coal.html.
13 Mercury: Basic Information. http://www.epa.gov/mercury/about.htm.
14 Mercury: Health Information. http://www.epa.gov/mercury/effects.htm.
15 EIA 2010 Year in Review, Exports and Imports, http://www.eia.gov/coal/review/coal_exports_imports.cfm.
16 EIA International Energy Outlook 2010 - Coal, http://www.eia.gov/oiaf/ieo/coal.html. For a discussion of other factors impacting U.S. coal prices and world competition, see id. – Future Role of the United States in World Coal Trade, Report #:DOE/EIA-0484, July, 27, 2010,http://www.eia.gov/oiaf/ieo/wct.html.
17 Id., see also Parker, Mario, Norfolk Southern Sees More Coal Export Demand, China Shipments, Bloomberg.com, Oct. 9, 2009, http://www.bloomberg.com/apps/news?pid=conewsstory&tkr=ANR:US&sid=aKVID1s4nOY8#; McCabe, Robert, After Rough Year, Coal Exports Look to Rebound, The Virginian Pilot, Oct. 18, 2009, http://hamptonroads.com/2009/10/after-rough-year-coal-exports-look-rebound.
18 The Alabama Port Authority owns McDuffie, which has capacity to ship 30 mil. short tons of coal per annum. http://www.asdd.com/facilities_mcduffie.html. If one clicks the photo on this page, there is a larger image showing a coal terminal operating at 15.6 mil. sta.
19 Owned by Norfolk Southern Railroad, Lamberts Point has capacity to ship 48 mil. short tons of coal per annum. http://www.nscorp.com/nscportal/nscorp/Customers/Coal/Transload/lamberts_point.html.
20 SSA, the proponent of a coal terminal at Cherry Point, obliquely claims that U.S. coal will reach China, but through Canadian ports if its terminal is not built, e.g. http://www.gatewaypacificterminal.com/economic/national.shtml, but this is not true. Canadian ports are at capacity. ______________ [discussion & support]
21 Factbox-- Proposed, Existing Capacity for U.S. Coal Exports, REUTERS, June 9, 2011, http://www.reuters.com/article/2011/06/09/usa-coal-exports-idUSN0915182220110609; see also http://en.wikipedia.org/wiki/Ambre_Energy, http://en.wikipedia.org/wiki/Arch_Coal.
22 SSA’s parent company, Carrix, announced on July 5, 2007, that Goldman Sachs Infrastructure Partners “committed to a significant equity investment in the Company, positioning Carrix to capitalize on the substantial growth opportunity in the global port operations industry.” http://www.ssamarine.com/070607.html. Goldman Sachs bought a 49% interest in Carrix/SSA, leaving the Hemingway family’s CEO, Jon Hemingway, in place to proceed with the company’s operations, and “giv[ing] SSA the financial resources to pursue technology and expansion projects.”Goldman Sachs Acquires 49% Equity Stake in SSA Marine, AMERICAN SHIPPER, June 6, 2007,http://www.americanshipper.com/CPC/CPC_story.asp?news=62743. 23 Earthjustice sued on behalf of Climate Solutions, Columbia Riverkeeper, Sierra Club,and Washington Environmental Council. Earth Justice Press Release, Dec. 13, 2010, http://earthjustice.org/news/press/2010/coalition-challenges-permit-allowing-dirty-coal-export-to-asia-from-wa-port.
24 Olson, Erik, Millenium Offers to Delay Coal Exports, Conduct Environmental Review, The Daily News, Mar. 7, 2011, http://tdn.com/news/local/govt-and-politics/article_cbcdfc36-4921-11e0-b022-001cc4c002e0.html.
27 Documents pertaining to the current permitting process, including historical documents, have been compiled by the state at a secure website, after creation of a “MAP,” or Multi-agency Permit, Team by the Governor’s Office of Regulatory Assistance. http://www.ora.wa.gov/documents/map_information.pdf. Due to the myriad permits required from federal, state, and local regulatory bodies for construction projects of large magnitude, the governor’s office created the MAP system to facilitate communication and to “streamline” the process. Supposedly accessible by the public, one must gain permission to access the secure server hosting the MAP Team web page for the SSA project – referred to as “GPT” -- by requesting the User ID (“CherryPoint1”) and a password. E-mail MAP Team Project Lead Scott Boettcher, firstname.lastname@example.org, or call 360-480-6600.
28 In Re: Major Development Permit and Shoreline Substantial Development Permit by Gateway Pacific Terminal, Findings of Fact, Conclusions of Law, and Major Development Permit and Shoreline Substantial Development Decision, Council of the County of Whatcom, Washington, File Nos. MDP92-0003 & SHS92-0020, Mar. 19, 1997, https://secureaccess.wa.gov/ofm/iprmt24/Portals/_1357/images/default/MDP%20SHS%20Permits.pdf.Those permits, at page 10, seem to indicate shipping volume in excess of 8.2 mil. tons, or other commodities, would require additional permitting from the county.
30 The environmental co-appellants are North Cascades Audubon Society, Ocean Advocates (which no longer exists), People for Puget Sound, and Washington Environmental Council. https://secureaccess.wa.gov/ofm/iprmt24/Portals/_1357/images/default/17%20Settlement%20Agreement.pdf.
31 Settlement Agreement, Pacific International Terminals, Shoreline Substantial Permit No.SHS 92-0020 & Shoreline Hearings Board Nos. 97-22 and 97-23, Appendices A-F, https://secureaccess.wa.gov/ofm/iprmt24/Portals/_1357/images/default/Settlement%20Agreement.pdf.
32 Gateway Pacific Terminal JARPA Project Information Document Ch. 4, The Proposed Action at 4-49, 51, https://secureaccess.wa.gov/Portals/_1357/images/default/GPT_PID_Ch4_2011-02-28.pdf.
33 https://secureaccess.wa.gov/Portals/_1357/images/default/ GATEWAY%20PACIFC%20TERMNAL%20PROJECT%20JARPA%2020110228(3).pdf.
34 EIA Annual Coal Report 2009 No. EIA/DOE No. 0584, Feb. 3, 2010, http://www.eia.gov/cneaf/coal/page/acr/table10.html
35 Peabody Energy to Export Up to 24 Million Metric Tons of Coal Through Gateway Pacific Terminal, Coal Geology, Mar. 3, 2011. http://coalgeology.com/peabody-energy-to-export-up-to-24-million-metric-tons-of-coal-through-gateway-pacific-terminal-in-whatcom-county/14824/.
36 The county created a web page where it posts GPT permit related documents: http://www.co.whatcom.wa.us/pds/plan/current/gpt-ssa/.
37 The Sierra Club, Climate Solutions and Re Sources retained Earth Justice, the firm that challenged the Millennium Bulk Terminals permit in Longview. The Earth Justice letter to Whatcom County can be read at http://www.sierraclub.org/coal/wa/downloads/Whatcom_County_Letter.pdf.
38 Tyler R. Schroeder, Whatcom County Planning Supervisor, to Cliff Strong, Pacific International Terminals, Inc., June 23, 2011, http://www.co.whatcom.wa.us/pds/plan/current/gpt-ssa/pdf/20110623-gptdetermination.pdf.
39 Pacific Int’l Terminals, Inc., Project Information Doc. Ch. 4, The Proposed Action, Table 4.5, Trains per Day by Operation Phase at 4-53. https://secureaccess.wa.gov/Portals/_1357/images/default/GPT_PID_Ch4_2011-02-28.pdf.
41 Stark, John, Hundreds Turn Out to Mayor’s Cargo Terminal Meeting, Bellingham Herald, June 2, 2011. http://www.bellinghamherald.com/2011/06/02/2041354/hundreds-turn-out-to-mayors-cargo.html.