My name is James (Jim) Robitaille. I have been a Bellingham resident for over 12 years. My family and I moved to this area because of the natural beauty, available outdoor activities, clean air, water, low crime rate, healthy living conditions and the pristine Mountain and Island locations for all to enjoy. We were also attracted to the area because of the favorable cost of real estate, cost to feed a growing family and overall cost of living. In our search for a new home, we were also specifically looking for an area which provided quality academic opportunities at all levels of development. Bellingham meet that challenge in every way. We have three children and they have each enjoyed attending elementary, high school and Western Washington University while living here in Bellingham. Bellingham is and always will be our home. It is for that reason that we each have serious concerns about the changes a coal terminal would have in our lives, to our health, and in our future economic opportunities.
I have spent the past year researching, studying and staying informed about the many issues involved in this complex plan SSA Marine and GPT has put forth. I have tried to identify many of the pertinent concerns that my family and I have, along with what this community would like answers to. With that in mind, below I have compiled a list of scoping comments for the lead agencies to address and examine. I wish that this was an easy process with easy answers to our concerns. However, I realize that this is a very complex process of the issues at hand. Many necessary questions will be asked that need answers in order to ensure that we all, both local and global communities are taking the steps to provide sustainable solutions to living in an industrialize world. Answers which first protect it's community at all levels, with attention to the health of it's residents and other living creatures and/or organisms that share our ecosystems. While also not forgetting it's community cultural wellbeing, established ways of life and the existing economic income enjoyed by all.
While I would like to say more, I will make my intro brief and save you time so that you can focus on the real issues at hand, the concerns I have listed below.
Thank you in advance for your review of these issues and I look forward to your completed answers to these and many other concerns the people of Whatcom county have regarding the GPT proposal. I trust that before permitting GPT's plan is approved, that each and every community concern is fully explored, impacts thoroughly studied and all explained in the final draft scoping statement.
As I have posted a variety of concerns, I have listed each concern based upon specific topic heading and hope this has been helpful.
A.) Blocked Emergency Response
The critical issue of emergency vehicles, fire, ambulance and police, or any other vehicles taking personnel to hospitals and those responding to an emergency will be delayed at train crossings at a time when seconds mean life or death to a patient and residents needing help.
1. Examine the effects that 9 to 18 additional trains , at one and half mile in length will have on delays for first responders at-grade crossings throughout Whatcom county and especially in city of Bellingham where pollution density is much greater.
2. How many crossing are there throughout the county and in the more densily polluated area of Bellingham and what type of mitigation would reduce these delays.
B.) Railroad Crossing Hazards
Although SSA Marine promotes the fact that they will be paying $10 million annually in taxes, many of us think that amount is inadequate considering the anticipated public investment required. Those investments would be in upgrades to rail safety, yet federal law prohibits railroads from paying more than ten percent of cost for safety improvements such as at-grade crossings. Since the increased train traffic levels obviously require significant safety improvements, this will seriously impact public budgets at a time when most city are experiencing current deficits. .
1. Examine the number of at-grade crossings that would have to be bridged to provide the necessary safety requirements.
2. What the total cost would be including other safety upgrades required for the added train traffic.
3. A specific breakdown of the economic feasibility and who exactly would be responsible for these costs.
C.) Coal Dust Along Transportation Route
Proponents of the project will argue that state-of-art best management practices will be employed in every aspect of the handling of the coal, but researching other terminals, places like Seward, Alaska where the railroad and coal company are currently being sued for Clean Water Act violations, or Robert’s Bank in British Columbia where oxygen depletion is being observed in near shore habitats. Additionally, coal dust is an issue at a marina five miles south from the facility. In these cases, as in others, performance speaks much louder than promises.
Mercury, Arsenic and other Heavy Metals naturally occurs in coal: Mercury pollution is a serious threat to human health with pregnant women and the unborn being most vulnerable to this peril. With the smallest amount of these deadly and carcinogenic properties being present in either our water systems (leaching down into our aquifers) or being blow into our rivers, streams, sea water, onto eel grass and herring spooning grounds at Cherry Point, each would have detrimental effects on all living organisms.
Initial estimates of coal shipments to Cherry Point are put at 24 million metric tons. Moving up from 24 to 48 million metric tons of coal annually in uncovered rail cars within a short period of time is a tremendous undertaking requiring at least nine additional full, nine empty, mile-and-a-half long trains daily traversing to and from Cherry Point through downtown Bellingham. According to BNSF’s website, these 15,000-ton trains will lose three percent of their load in transit or 1,780,000 short tons of coal dust spread annually (that's with the application of the chemical resin sprayed on the coal before leaving the mines) from the Powder River Basin to the terminal. So, in addition to increased noise, diesel exhaust and traffic delays, the City's and County's all along the rail line will also have to deal with a significant increase in coal dust accumulating in our neighborhoods and waterways.
1. On behalf of my family and our entire community, I petition the lead agencies to study the evidence demonstrating the amount of coal dust lost per train load in spite of spraying chemical adhesives/resins onto coal before transporting it.
2. To study/examine the effects of burning these adhesives/resins with coal and what additional air pollution might be created from this cocktail of chemicals.
3. To study the effects of what the loss of 3% or 1,780,000 metric tons of coal dust will do to our farm lands, water ways and air quality along the rail lines here in Bellingham and throughout Whatcom county. (I also strongly ask that a full Programmatic study (PEIS) be conducted, demonstrating the impact from the Powder River Basin to Cherry Point).
4. Examine the effects of inhalation of coal dust by people and all other living species. Specifically how it may have an increased effect on respiratory health especially for seniors, children and those suffering with Asama.
5. Focus study on the disproportionate impact on low-income communities which tend to be situated closer to transportation corridors and the cancer rate and respiratory problems of these residents compared to other parts of Bellingham city environment.
D.) Diesel Em missions
Diesel particulate matter (DPM) that is less than 2.5 microns in size, the most dangerous size, is emitted by the coal train locomotives. These particles go deep into the lungs of people who breathe the fumes and have been found to cause serious health effects including cancer.
The U.S. Environmental Protection Agency calls reducing pollution from diesel engines one of the county's most important air quality challenges. Diesel engines can produce large quantities of smog-forming nitrogen oxides and soot, which can cause lung and heart problems. Soot also plays a significant role in climate change, researchers say.
Studies on the impact of train-generated diesel exhaust in Stockton, California indicated a clear relationship between the proximity to train traffic and cancer. This study observed a doubling of cancer rates within a zone of 200 yards of the rail operations. While Bellingham projected traffic levels are less than Spokane or Stockton, the relationship between diesel particulates and cancer is well-documented at multiple locations.
1. Examine the amount of diesel pollution produced by the added amount of 9 to 18 additional trains per day traveling throughout Whatcom county, and especially in the densely populated area of the city of Bellingham.
2. Examine the need to conduct air monitoring adjacent to and downwind of transportation corridors and not just at fixed site monitoring stations.
3. Monitoring can be conducted at existing operational coal terminals in the U.S. and British Columbia, and it is possible for this type of monitoring to be done now, extrapolating the geography, winds, and volume proposed at GPT. Additionally, the studies must include all rail communities from the terminal site at Cheery Point back to the mines at Powder River Basin.
E.) Property Values
The City of Bellingham alone has roughly $15 billion in real estate value which will be potentially devalued by noise (wheel squeaking and horn blasts), coal dust, and traffic.
Property value drops as small as one percent can have tremendous consequences in terms of individual worth. These potential impacts need to be addressed in the public discourse.
Vibration from the extremely heavy coal trains has the potential to trigger landslides or land subsidence, especially when the ground is saturated as it did recently. This would have a devastating effect on homes above and below the rail lines, especially around the chuckanut ridge area.
Additionally, nobody wants to live or work in, or visit, a coal town, for good reason. The coal terminal and related traffic will damage the reputations of all affected communities, which in recent years, Bellingham has spent millions of dollars building it's tourism business.
Coal trains are long and heavy (i.e., one and half miles long and up to 15,000 tons). These trains are so heavy that they tend to flatten the rails, which causes much of the wheel squealing we hear during transit. These same extraordinary forces that impact tracks also act on geology. Given that much local development is on vulnerable or unstable formations such as the homes along Eldridge Avenue in Bellingham, this is a great concern that needs to be examined.
1. Examine the effects of 18 additional coal trains will have on property values from the added noise and train traffic.
2. Study to determine safety issues caused by the heavier coal trains in triggering landslides.
3. Examine the increased diesel and coal dust particle pollution on property values.
F.) Quality of Life Issue
Noise from the coal trains throughout the day and night will interfere with sleep, distract children at school, and disrupt business. This noise impairs cognitive development especially in children, but can effect productivity in adults and has other impacts in people of all ages.
1. Quality of life is a great concern that needs to be examined. Loss of sleep creates loss of productivity, increases irritability and causes general malaise in people.
2. How can the noise issue be mitigated and at what cost?
3. Who will be responsible to pay that cost.
Just in the past few months there have been two major train derailments on the West Coast. The likely hood of a coal train derailment is extremely high considering the terrain and distance they have to travel to a West Coast terminal. Add to this issue the overall weight and length (one and half miles long) of these trains, and the effect they have in continuing to erode the stability of the rails because of their weight. As these coal train travel along the coast, much of this territory is right at waters edge. If a coal train were to derail and coal gets deposited into these waters, it would destroy spooning grounds, vegetation, fishing and crabbing for many residents, and could even devastate oyster beds here locally in Bellingham Bay for many years.
1. Please examine what precautions or safety measures that would be put in place and how these companies would prevent derailments, especially along the coast line.
2. In the event of a derailment, examine how they would mitigate or clean up a spill/derailment of this magnitude.
H.) Physical Disruption:
This project proposes to change the physical characteristics of the site in a significant manner including impacting 162 acres of wetlands and altering more than 2 miles of existing waterways. High levels of vessel traffic in the area will also impact near shore and offshore conditions, particularly bulk carriers that are more prone to catastrophic failures. Since this area could provide habitat or needed ecological function for 12 federally protected species and seven state protected species, the exact extent of these modifications is extremely important.
In addition, I am particularly concerned about the vulnerable Pacific herring populations (a Dashboard Indicator for the Puget Sound Partnership’s recovery efforts) that spawn in eel grass beds in the near shore habitats around Cherry Point. This formerly robust population—now at five percent of historic levels—was once a key building block of a critical food chain that starts with plankton and ends with salmon, orcas and humpback whales....and of course us people who love salmon. Any action that impacts eel grass or otherwise jeopardizes this population further will have ecological as well as potential economic impact via lost fishery or tourism revenues.
1. Examine the impact this terminal would have on all 162 acres of wetlands and to what extent this issue can realistically be mitigated.
2. Study the impact that this enormous size pier/dock would have in altering the geology of this site, along with the effects on the 2 miles of existing waterways surrounding this dock.
3. Examine the effects the initial construction would have on both the eel grass at shore level and long term effects on eel grass from the physical activity at this site.
4. Examine the direct effects that fugitive coal dust will have on existing eel grass at Cherry Point.
5. Examine the direct effects that fugitive coal dust will have on the critical herring population.
6. Examine the direct effects that fugitive coal dust will have on deterring sustainable habitat or needed ecological function of the 12 federally protected species and 7 state protected species in the waters surrounding Cherry Point, and the exact extent of these modifications, if any.
7. Examine the direct effects that fugitive coal dust will have on the oxygen levels in the sea water of the bay around Cherry Point, including what the total distance or miles effected would be.
8. Examine the amounts of regulated and non-regulated pollution caused by fugitive coal dust, diesel particulate, spilled engine oil and the like as can be measured at current terminal sites at Roberts Point and else where.
9. Examine the effects of over one thousand transits of vessel traffic to the proposed GPT dock and it's potential disruption to the spooning of herring, along with 12 federally protected species and 7 state protected species in the waters surrounding Cherry Point
10. Please examine the destruction of the existing forested area and the overall impact this will have on the the natural habitat of existing animals in the area, as well as effects on the ecosystems surrounding Cherry Point and if this could realistically be mitigated.
11. Examine the size of the railroad spur suggested by GPT, its size, it's location on the property and it's impact on the lands ecosystems.
Cultural Impacts at GPT Sites
I.) First Nation Rights:
The purposed GPT site, known by its traditional name Xwe'chi'eXen, is considered a significant cultural site and an ancestral burial ground by the first nations people of the Lummi tribe. Their claim to the site's historical significance extends back hundreds of years, as it was a village site where the Lummi have fished, gathered and lived for over 175 generations. Cherry Point (Xwe'chi'eXen) is listed on the Washington state heritage register of culturally significant places.
Ancestral Burial Site: The terminal and surrounding sites are part of an ancient Lummi village, and as such is considered by the Lummi people to be an ancestral burial site. Though the bones of Lummi ancestors were removed from the site during archaeological excavations of the 1940's and 1950's, the site remains sacred to the Lummi Nation, who has long opposed development of this property.
Historical Reefnet Site: For thousands of years before European settlement, Lummi people fished at Cherry Point (Xwe'chi'eXen). The Lummi developed a unique reefnet technology to harvest salmon at the site while limiting by catch quantities. The sites traditionally used for this purpose (Sxwo'le) are protected by treaty and are considered both critical economic resources and historically significant areas.
Treaty Fishing Rights: The Lummi people are signatories to the Point Elliot Treaty of 1855, which guaranteed the Lummi and several other Coast Salish first nations access to traditional fishing and gathering sites. In 1975, the Ninth Circuit Court of Appeals upheld a federal court decision issued in 1974 by District Court Judge George Hugo Boldt that affirmed the rights of the Coast Salish tribes to serve as co-managers of the Puget Sound salmon fishery. The threat posed by the coal terminal proposal to salmon habitat and fishery stocks has the potential to significantly impact the treaty and inherent rights (Chi'lang'e'lh) of the Coast Salish tribes to their traditional way of life.
1. Examine the rights given to the first nation people of the Lummi tribe to claim this property as a heritage site and sacred ancestral burial site to be untouched by development.
2. Examine the potential spiritual effects on first nation peoples of the Lummi tribe if this heritage site were no longer available to them and their ability to honor their ancestors there.
3. As signatories to the Point Elliot Treaty of 1855, please examine how this terminal would directly impact their ability to continue to fish and crab this area due to the potential increased pollution, the dead zone created by fugitive coal dust and the amount of disturbance from one thousand vessels transits to GPT dock.
J. )Fire Hazard at Refineries Caused by Fugitive Coal Dust
Coal dust is highly combustible. With two oil refineries within one mile apart in either direction from the GPT site, it should be a worry some concern. When coal dust is blown from these 80 foot high coal piles at the terminal during seasonal storms that bring 40 to 60 miles per hour winds to the area and onto one of the two nearby refineries sites, it could potentially create a fire hazard or other industrial hazardous condition.
1. Examine the direct effects that fugitive coal dust may have on local refineries, including fire hazard, equipment failures and human safety issues.
K.) Water Source, Usage and Storage at GPT Site
There has been a lot of discussions about fugitive coal dust at GPT site. According to the GPT website, their plan to control coal dust from blowing off these numerous 80 foot high coal piles is to spray fresh water on these piles. This will be a continuous spray of water onto the coal piles in order to manage the coal dust, and to also help GPT minimize the risk of spontaneous combustion of these coal piles, (a common problem with Powder River Basin coal). This fresh water source will come from one of two recently drilled wells which the city of Ferndale is now using as their source of city water to all their residents. (Prior to these wells being dug, the only available water source for GPT would have been supplied from the Nooksack river, which is already experiencing reduced flows). It is estimated that approximately 1.5 million gallons of water will be used per day in the process of wetting down the numerous stock piles of coal. GPT plans to capture some of the run off from this water and collect it in plastic lined pits or water storage areas for recycling and re-use. I have serious concerns about the volume of water to be used in relationship to the size and available amount of water in the existing aquifer to service both GPT and Ferndale's residents. Additionally, the land where the coal is stored will be saturated by water. This contaminated water will then drain down into the ground and potential into this the same aquifer suppling water to Ferndale's residents and or Cherry Point bay water.
1. Examine the quantity or actual volume of water that could be supplied by these new wells.
2. Examine if GPT volume of water used will effect the water needs of Ferndale residents.
3. Examine what monitoring measures will be put into place to safeguard the quality of this drinkable water for Ferrndale residents and who will it be responsible for monitoring.
4. Examine the the size of these recycling ponds, acreage needed and how these ponds will be constructed, height of retaining walls, type of liner and its rate of degradation in order to protect the ground from being contaminated.
5. Examine the feasibility of recycling this water and how GPT will dispose of the heavy particulates or slug without having a negative environmental impact.
6. Examine what precautions will be put in place to keep these ponds from overflowing during heavy rains, winds or storm conditions.
7. Examine if runoff were to reach the shore line at Cherry Point, what safety measures could be put in place to keep this contaminated water from reaching bay water, eel grass and herring spooning area.
Extended Programmatic EIS
L.) Shipping Coal to Asia:
Science has proven that carbon dioxide from both cars, trucks and industry are having a direct impact on climate change. The shipment of coal to China will result in more mercury in our water here locally. In fact, a 2005 study by the United State Geological Survey drew the conclusion that atmospheric transportation is the main source of new mercury in Lake Whatcom and other Washington waterways. Thus, burning coal elsewhere, like China or other Asian countries, will increase the amount of mercury in our waterways, increasing human and animal exposure to this element. As a community and residents sharing this planet with other species, we have a responsibility to do what is necessary to provide a sustainable way of life for all. As science continues to show us the negative effects of man's use of fossil fuels (including coal) on our environment with the direct impact on eradicating many species each and every day due to these and many other toxic chemicals accumulating in our air, water and land, it is increasingly important that we look at every action or decision we make and whether it increases or decreases the planets risk of destruction. I realize that this statement may sound outlandish, but at the rate that climate change alone is impacting our world, we shorten our existence one hundred fold every degree warmer the planet becomes. (Reading the New York Times today 1-15-13, under great pressure from numerous complaints from it's citizens, the Chinese government has finally admitted that air pollution is a growing problem in their country. The air in Beijing on Jan. 14th was “brown, soupy thick air which has been consistently rated as hazardous, and rated even worst by foreign monitors” said the NYT. And unfortunately, air quality in China is a direct result of their rate of economic growth, which has lead to building one coal power plant per week). But even in China and else where, governments are now realizing that this growth at any expense is not sustainable and they are looking at alternatives provided by green energy, wind, solar and the like.
1. Please examine at what rate the pollution generated in China and carried by the jet stream to the shores of Washington state are effecting the quality of our air, lakes, water systems and our farm lands and measure the amount of mercury, heavy metals and the cocktail of chemical which are being deposited here.
2. Examine the direct result of reducing the burning of coal will significantly reduce carbon dioxide in our atmosphere and help to reduce climate change, both locally and globally.
3. Examine if the mercury that is being deposited in significant amounts to our waterways is from China, then this permit for GPT to ship more coal to China should not be permit able.
M.) Pollution from Ships at Sea and at the Terminal Dock
Ships approaching and leaving the terminal will emit air pollutants, including sulfur oxides, nitrogen oxides, hydrocarbon PM, and carbon monoxide. These pollutants can have serious health effects on all living organisms. Cape sized ships emit large quantities of pollutants from burning bunker fuel, one of the dirtiest fuels anywhere. Emissions from 1000 transits of these coal laden ships as they cross the Pacific Ocean will contribute to regional and global quantities of greenhouse gases, toxic air pollutants, acid rain pollutants, and particulate matter. If and when these vessels enter US waters and continue to burn bunker fuel (illegally), the level of local pollution will rise exponentially.
1. Please examine the current regulations on how close to shore these cape size vessels can burn bunker fuel and if these laws need to be reevaluated/revised to provide broader protection.
2. Examine what safeguards are in place to enforce any and all regulations of burning bunker fuel and ensure compliance.
3. Examine the level of pollution generated by these ships in US waters and how this can be mitigated.
4. Examine dock side levels of pollution, including sulfur oxides, nitrogen oxides, hydrocarbon PM, carbon monoxide and how they will be monitored and potentially mitigated.
5. Examine how pollution from accidental oil/fuel/chemical spills from these ships will be monitored and mitigated.
N.) Foreign Cape Sized Vessels
In recent years, invasive species have caused havoc to both fresh water lakes and to our local ocean waterways. With up to an additional 1000 vessel transits being added to the number of foreign vessels entering our waterways, it seems inevitable that an accident or disregard for our laws will occur and ballast will be emptied either in our bay or at dock side. The amount and specific invasive species released in this area could be devastating to our herring, salmon, orca populations and could have a detrimental effect on this area's ecosystems. Unlike most of the current tanker vessels traveling in this area, cape sized ships (which are 10 times larger than most tanker ships currently coming into the bay), are the largest vessels on the water. And unlike the refinery ships which travel mostly within US domestic waters, these cape sized ships will all come from an Asian destination. Crossing the Pacific ocean empty of cargo, these ships are forced to fill their ballast with hundreds of thousands of gallons of water from their geographical regions so that they can have better control of these vessels in the open ocean, thus the huge potential problem with invasive species.
1. Please examine current regulations on how close to shore these cape size vessels can empty their ballast and if these laws need to be reevaluated/revised to provide broader protection.
2. Examine what safeguards are in place to enforce any and all regulations and ensure compliance.
3. Examine the potential risk that a release of invasive species would have on both the bays ecosystems and all fish stocks in this area.
4. Examine what attempts would be put in place to mitigate this potential problem.
O.) Shipping Lane Congestion
The narrow and complex shipping lanes between Cherry Point and the open ocean already have substantial traffic. Introducing more than 500 new, extremely large ships per year (1000 vessel transits) will make existing problems with shipping lane congestion substantially worse. An ecological risk assessment commissioned by the Washington department of Natural Resources concluded that significant increases of vessel traffic in our waters would “inevitably increase the risk of an oil spill”. And according to NOAA, an oil spill poses the greatest threat to the Southern residents, including the destruction of many ecosystems in that area. Alarmingly, these cape size vessels are single-hulled cargo ships and carry more fuel/oil for propulsion then all oil tankers in US waters. These enormous vessels servicing the purposed GPT don't require a tugboat escort, despite having the worst safety record of all sea going vessels. Should a coal laden vessel run aground, or worse, collide with an oil tanker, thousand of gallons of heavy bunker and diesel fuel, and oil, would spill into the inland sea. Yet not only is this risk of disaster in our local water ways and the Straight of Juan de Fuca, but all along the entire Great Circle route, through the Aleutian Islands at Unimak Pass, (an extremely narrow passageway) and out to the south China sea.
1. Examine the increased risk of collusion or ships running aground in the Straight of Juan de Fuca and Rosario Straight with the addition of up to 1000 cape sized vessels transits in these waterways.
2. Examine the safety requirements for these enormous cape sized ships and establish the need to be escorted by tugboats.
3. Examine how a collision of these coal leaden ships would be handled and what clean up measures need to be put in place due to the inevitability of this happening.
4. Examine the need to establish a disaster response vessel(s ) for the Puget Sound region as required by companies drilling oil.
5. Examine how the desired route to China through the Aleutian Islands should be better controlled, monitored and passage prohibited at times of extreme weather.
6. Examine the potential of requiring an alternative route then through the Aleutians in order to reduce the potential collision risk or ships running aground an destroying this critical ecosystem.
P.) Blocked Rail Crossings
Frequently blocked crossings due to 9 to 18 additional coal trains may reduce the ability of businesses to attract customers and to deliver goods to their destinations. A large volume of coal trains going through downtown Bellingham will cut off the waterfront from the rest of town, impairing planned development, new jobs and have a negative effect on existing businesses.
1. Examine the economic impacts to existing and future businesses caused by the large volume of additional trains going through Bellingham.
2. Examine the needed mitigation to counter these delays and the economic feasibility.
3. Determine who would be responsible for cost and upkeep of these mitigations.
Q.) At-Grade Crossing Improvements Costs
Building bridges and bypasses to avert the delays caused by at-grade crossings are expensive. Local communities are generally required to pay for at least 90% of the costs of rail crossing improvements that are needed to deal with the increased train traffic. Most of these crossings are located within the city of Bellingham. With current Bellingham fiscal budget running at a deficit, how would these improvements be paid for by Mayor Linville and city government?
1. Examine at-grade crossing alternatives to allow for a better flow of traffic
2. Examine the economic feasibility of these improvements and who would be responsible for the cost of these crossing alternatives, along with what the total cost per bridge /overpass would be.
R.) Additional Safety and Rail Upkeep
Coal dust from coal trains damage the tracks, increasing maintenance costs and impair rail safety for all trains, including other freight and passenger trains, while also increasing the chance of derailments.
1. Examine BNSF studies regarding the problem associated with coal dust on rail systems.
2. Examine the need for frequency of safety inspections and who is responsible for monitoring these safety checks.
3. Examine who is responsible for the cost of this rail safety and up keep.
S.) Impeding the Growth of their Commodities and Freight
A large increase in coal trains (9 to18 trains per day) will have the effect of splitting communities at the rail line, to a greater extent than any current effects, by impeding free flow of people (including AmTrack) and traffic for personal and business reasons.
1. Examine what the overall effect of up to 18 additional trains would have on existing train traffic which may cause delays and/if the impact would cause higher cost of freight.
2. Examine the need for a spur or siding to allow for trains to pass and where this siding would be built.
3. Examine if a siding were determined necessary, at what cost and who would be responsible to pay.
T.) Impaired Development of High Speed Rail
If the existing lines receive a large increase in rail traffic, it would make it impossible to deploy high speed rail. A vast increase in coal train traffic will also interfere with existing cargo train traffic and important passenger lines. On a single track, passenger trains are typically required to pull into a siding to allow a coal train to go by. And when coal trains fully use all of the available rail lines, it will impair the use of the same lines for growth in passenger service, which means more traffic will be diverted onto roads such as I-5. With more truck and car traffic, there will also be increased road congestion due to added road construction periods which would have a direct effect on all businesses depending on the smooth flow of services brought to them by truck transportation.
1. Examine what the overall effect of up to 18 additional trains would have on existing passenger train traffic and what delays may be caused and/or if there would be a higher cost to ridership.
2. Examine the need for a spur or siding to allow for trains to pass and where this siding would be built.
3. Examine if a siding were determined necessary, at what cost and who would be responsible to pay.
U.) Giving Away U.S. Natural Resources
Congress has auctioned off property in Powder Ridge Basin which is rich in coal reserves to companies like Arch coal and Peabody Energy for a fraction of the cost of the land. This basically amounts to subsidizing these companies. In the past, most of this coal was used domestically in order that the U. S. economy could have cheap energy from coal fired power plants. As BLM land, the coal in the ground is owned by the U.S. Government and we the tax payers. But this coal is provided to the big coal companies for less than $1 a ton, a fraction of its actual value. An examination needs to be conducted on whether we should REALLY allow this resource to be sold at the same price when the purpose of this coal being shipped to China is to further increase their manufacturing capacity, at a time when so much of American industry has been outsourced to Asia and while this Country is facing it's largest deficit in U. S. history.
1. Examine if US domestic pricing for BML land should be offered to coal companies who will ship this natural resource to Asian countries.
V.) Require a Terminal Bond to be Place by SSA Marine/Goldman Sachs
SSA/Carrix should be required to post a bond of 500 billion dollars or more, and many think that more would be adequate. By simply measuring the cost of a worst-case scenario, from a spill of 470 thousand gallons of bunker fuel in the San Juan Islands, (a Cape size ship collision or one running aground accident) to an explosion at the terminal, or a derailment in a highly populated area like downtown Mt. Vernon. These accidents are feasible and communities need to be protected. In this case, a bond would be set up so that it is replenished as funds are withdrawn and make SSA/Carrix guarantee any and all damages associated with activities related to the terminal regardless of who is ultimately held by the courts to be liable – the coal owner (some subsidiary of Peabody Energy), the coal transporter (BNSF), or the terminal operator (PIT). Let SSA/Carrix fight it out in court for the next 25 years to get their money back if they’re not liable, but in the meantime, the public shouldn’t have to wait decades to receive the final paltry settlement the Supreme Court approves, a la Alaska citizens and the Exxon Valdez oil spill.(W hen Exxon was court ordered to pay $4.8 billion in punitive damages to Prince William Sound area because of their failed safety plan, the slick lawyers for Exxon got it down to $504 million... which amounts to a month worth of their profits)
GPT’s Whatcom application states that a “site-specific emergency response plan would be developed and kept available at the Terminal at all times. Spill and response measures would be implemented following an emergency or release of dangerous materials... coordinated with ALCOA and BP.”
However, we don't have to look back very long to remember the BP Gulf Oil Spill emergency response plan? And after Fukushima, radioactive iodine 131 was fed to infants through tainted drinking water. Keep in mind that all these situations, Bhopal, Chernobyl, Three Mile Island, BP Gulf spill, Exxon Valdez spill...all had a safety plan.
Make these mega-rich corporations pay an up-front $500 billion dollar damage deposit so silk stockinged lawyers can’t make taxpayers take another hit when a Frankenstorm hits or an earthquake or volcano or all of the above happen. Force them to prepay that GPT safety plan and we’ll use dirty money to develop clean energy and real living wage jobs!
1. Require a substantial bond (at least $500 billion) be placed by SSA Marine which would cover damage costs if or when an accident were to occur, enabling communities to act/react immediately to the crisis.
Thank you for your time and effort to mitigate this problem.