How Much Coal Does One Train Car Hold
Key Facts
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OVERVIEW
There are currently plans to develop the largest coal export facility in North America at Cherry Point, in northwest Washington state. The Gateway Pacific Terminal, a project of Pacific International Terminals, would be owned by SSA Marine, which is owned by Carrix, partnered with Goldman Sachs. Coal mined from the Powder River Basin by Peabody Energy would be hauled by trains along BNSF rail lines. The coal train corridor extends from mines in Montana and Wyoming through Sandpoint, Idaho to Spokane, down through the Columbia River Gorge, then up along the Puget Sound coast, passing through Longview, Tacoma, Seattle, Edmonds, Everett, Mt. Vernon, Bellingham, Ferndale and all points in between.
Costs to local economies, public health, and rail corridor communities are concerning to many. There is evidence to support that local jobs and businesses, property values, human health and quality of life would be adversely impacted by the coal trains. Increased marine traffic and the coal terminal would affect fisheries, marine ecosystems, and air quality. Substantial taxpayer investment may be required to support infrastructure required by the project and to mitigate some of the potential negative effects. There are questions as to whether damages to local businesses, regional identity, communities and fisheries could ever be adequately mitigated. The global impacts of coal export and coal combustion are significant, particularly when the present and future are considered.
WEST COAST COAL EXPORT
Photo courtesy Paul K. Anderson
China is building at least one new coal-fired power plant every week and has a seemingly limitless appetite for coal. The Powder River Basin in southeast Montana and northeast Wyoming has a seemingly limitless supply. There is increasing interest linking this supply with Asian demand through west coast coal terminals. Two potential sites in Washington state—Gateway Pacific Terminal at Cherry Point (Carrix/SSA Marine, Peabody Energy) and Millennium Bulk Terminal at Longview (Ambre Energy, Arch Coal)—are currently the most active projects, although other sites both in the States and in Canada are under consideration.
Coal mining and coal transport (by both rail and sea) are problematic when conducted at such scale. Local economies, communities, and human health are foremost amongst concerns. The coal industry itself acknowledges that coal markets are traditionally volatile and that coal terminals are financially risky ventures. Strategic questions regarding the wisdom of selling energy resources cheaply to an economic rival have been raised. Additional concerns include those about the coal combustion that occurs once the PRB coal reaches its market.
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China consumes coal at an ever-increasing rate due to its burgeoning industrial economy. Though China has vast coal supplies of its own, dangerous mines combined with overrun rail infrastructure make it easier for China to import coal from other countries rather than mine its own. China has committed $80 billion over the next decade to build up its passenger rail in an effort to open up its main rail line capacity to move more coal. Washington State has put policies in place to phase out coal burning facilities because of coal's negative environmental impact, yet we are exporting it to China. Its unique economic position makes China especially powerful in negotiations of prices of coal worldwide.
The Powder River Basin (PRB) is an area in southeast Montana and northeast Wyoming known for its natural coal deposits. It is the largest source of coal in the United States. The Wyodak coalbed covers 10,000 square miles in the PRB and has seams of coal averaging 70 feet thick. Total production from the PRB was over 455 million short tons of coal in 2009. Powder River Basin coal is low-sulfur, subbituminous coal. While it contains 15 times less sulfur than Eastern (Appalachian) coal, it also has fewer Btu's of energy or a lower "heat rate," which means that coal-fired power plants need to burn nearly 50 percent more of it to match the power output from Eastern coal.
Coal is mined by a process called strip mining, a type of surface mining where overlying soil and rock are removed to reach the coal underneath. The mining process damages aquifers in the region, affecting human health and local economies, particularly ranching. Transporting tremendous amounts of coal from Powder River Basin mines requires an unprecedented intensity of railway usage.
This dedication of rail lines to coal transport is associated with a number of concerns, including, but not limited to, interference with passenger rail and other freight rail uses; impacts on other ground traffic, as railroad crossing delays escalate to hours per day; damages to local economies as businesses are isolated on the "wrong side of the tracks;" loss of tax revenues; effects of noise, vibration, coal dust and diesel emissions on human health, property values and quality of life. The coal train corridor extends through several states and communities that differ in size, demographics, and economic base; however, all communities would be subject to impacts from the proposed scale of coal export activities.
Although the Gateway Pacific Terminal and Longview, both in Washington State, are the two terminal sites with current proposals, other ports, including the Port of Grays Harbor in Hoquiam, Oregon International Port of Coos Bay, and Port of St. Helens are also under consideration. British Columbia ships coal from the facility at Westshore, at Roberts Bank; there is talk of expanding Prince Rupert's Ridley Island terminal; other locations in BC may be developed towards similar ends.
Sightline Institute has done research into the unreliable economics of West Coast coal export. An example of the false economic promise of coal export is the coal terminal in Los Angeles which was closed in 2006 due to market failure.
"Clean Coal" and the Powder River Basin
There is a compelling argument made by James Fallows in The Atlantic Magazine for making clean coal a priority, alongside "all-out effort on all other fronts, from conservation and efficiency to improved battery technology to wind- and solar-power systems to improved nuclear facilities." Clean coal refers to coal being used in more sustainable ways by sequestering the carbon dioxide emissions of coal. Fallows reports that China is a leader in developing clean coal technologies; these technologies, however, are still theoretical. A fundamental question remains: Is selling coal cheaply to China the best way to provide incentive to further develop "clean coal?" Selling an inexpensive energy resource that can be utilized with existing technologies may simply perpetuate the consumption of coal as we know it.
THE PROPOSED GATEWAY PACIFIC TERMINAL FACILITY
Photo courtesy Paul K. Anderson
The proposed Gateway Pacific Terminal (GPT) at Cherry Point would have a capacity of approximately 54 million metric tons of goods, of which 48 million tons would be coal , annually. By comparison, Westshore Terminals at Robert's Bank in the lower mainland of British Columbia, currently the largest coal port in North America, ships around 21 million metric tons of coal per year. The 2,980 foot long wharf would berth 3 ships; cargo would be conveyed along a 1,250 foot trestle linking the ships to shore. There would be an 80 to 105-acre stockyard at Cherry Point for storage of coal and associated machinery. Coal dust is generated from uncovered piles that need to be rotated regularly. The dust is notoriously difficult to control. The coal would be loaded from the storage areas into Panamax and capesize (too large to fit through the Panama Canal and must sail around a cape) ships for transport to destinations in Asia. As both supply and demand for Powder River Basin coal are vast, and as the current application is to develop only 350 acres of a 1,092 acre site, there is no way to accurately predict how large the Gateway Pacific Terminal might eventually become, and how many coal trains and vessels would then be required.
TRAINS
Photo courtesy Paul K. Anderson
Transporting coal from the Powder River Basin to proposed west coast terminal sites would require unprecedented levels of regional rail usage. There are concerns not only about dramatically increased rail traffic, but also about negative impacts associated with coal trains specifically, due to train length, weight, content, and polluting capacity. The terminal at Cherry Point would see the addition of approximately 30 miles of coal trains daily to the BNSF rail line that runs along the Puget Sound coast. This would likely constrain passenger rail and adversely affect the transport of freight other than coal. The Washington state rail system is already nearing practical capacity; infrastructure would need to be upgraded to accommodate proposed usage. BNSF has been largely silent on the issue of rail improvements ; it remains unclear who would pay, and what kind of physical and economic disruption such upgrades would cause.
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Train number, size, weight and type:
There are various numbers given for the number of trains per day required to transport 48 million tons of coal per year from the Powder River Basin to the proposed coal terminal at Cherry Point. According to Carrix/SSA, the total number of coal train trips per day (arriving full, leaving empty) would be in the range of 16 to 18 (9 loaded and 9 returning). Each of the coal trains would be approximately a mile and a half in length, made up of 125-150 cars, depending on car size and type. There is no cap on the number of trains possible, should the proposed terminal expand capacity in the future.
According to the Whatcom Transportation Plan of 2007, there are currently about 35 trains that run each day between Seattle and Everett, and 14 trains each day between Everett and Brownsville, BC. This means that between Everett and the Cherry Point coal port, there would be upwards of 30 trains total a day. Each loaded coal car (an open-top gondola or bottom dump hopper or bottom dump rapid discharge railcar) weighs an average of 143 tons. Due to this extreme weight, each 125-150 car train requires four to five locomotives, and therefore has at least four times the impacts due to diesel emissions of a single-locomotive train. The heaviness of the trains also produces more noise. There are lingering questions about the impact of the trains' weight, including their long-term impact on the rail system and potential damage to nearby structural foundations due to the trains' vibrations.
Coal dust:
Coal cars are typically uncovered; each car loses between 500 pounds and one ton of coal dust en route. Coal dust is a proven nuisance for rail lines; fugitive dusts degrades the ballast of the rail lines, and can be a cause of derailments. While adverse effects of coal dust from mining and combustion on human health are well-documented, the effects of coal dust blowing and/or leaching from coal cars on human health and on local water safety are as yet unknown.
Passenger Rail:
Rail lines like BNSF's Burlington–Ferndale route are projected to exceed practical capacity by 2015, causing delays and interruption in the service quality to passenger rail. There is also evidence to suggest that the increased number of freight trains along the corridor would preclude the development of high-speed passenger rail in the area.
Bottlenecks and infrastructure problems:
In some places along the rail corridor, the trains are on single tracks. These areas, along with other tunnels and bottlenecks along the corridor, could be severely impacted by an increase in the number and size of trains. Other trains, most notably passenger rail, could be forced off the tracks for extended periods of time. In addition, idling rail engines produce a significant amount of diesel emissions, resulting in environmental damage and raising health concerns.
Agricultural and other freight:
Because freight railroads who own the track (i.e. BNSF) are focused on obtaining maximum benefit and revenue from each available train slot, Washington State's manufacturers and agricultural shippers who need low-cost, shorter haul carload service are being outbid and priced out of the rail market by high-volume shippers. Specifically, BNSF is giving preference to intermodal (double stack container trains that move as a unit from origin to destination with no or few stops) and coal (longer trains carrying more cars) contracts. This is squeezing out Washington's industrial (lumber, wood product producers, manufacturers, waste management, and mining) and low-density agricultural product (apples, wheat, other fruit, potatoes) shippers—making it more expensive for them to use rail and forcing them to consider other options of delivery like trucking, which could negatively impact the consumer, increase air pollution, and even force businesses out of state.
Rail system capacity issues:
A number of factors determine capacity including the number of tracks and sidings, topography, mix of train types, the efficiency of terminals and rail yards receiving traffic, track speed, and power of locomotives. Generally, for a single rail system, capacity is in the range of 16 to 30 trains a day. Already nearing capacity, the Washington State rail system is being further strained by the increased demand of longer (8,000-foot) trains carrying higher-volume freight (coal). Because rail traffic is a system, capacity issues caused by infrastructure shortage somewhere along the route or other constraints can cause delays throughout the system. In its most recent Freight Rail Plan, WSDOT's projections for coal freight (estimated at 19.9 million tons in 2030) were based in part on BNSF's statement that it had "no public plans to increase capacity… for the foreseeable future" along the I-5 corridor. Yet, in February 2011, Peabody Energy and SSA Marine entered into contract to export (with BNSF agreeing to haul) 24-48 million metric tons of coal per year along the I-5 corridor to Cherry Point—effectively doubling even the highest projected level of coal freight related to managing capacity issues.
BNSF basics:
BNSF, owned by Berkshire Hathaway (Warren Buffett), operates in both the United States and in Canada, and transports coal across the border at Blaine, in Washington, and also in the Midwest. The railway privately owns and operates the tracks in Wyoming, Montana, Idaho and Washington. Historically, railroads have been accorded extraordinary rights (i.e. eminent domain) and protections (i.e. exempt from paying more than 10% of costs related to safety and the mitigation of adverse affects due to rail usage). BNSF has announced its plans to haul the coal (24-54 million mtpa) from Peabody Energy's PRB operations to the proposed SSA International Gateway Pacific Terminal at Cherry Point, where it will be shipped to Asia. Additionally, BNSF along with the Union Pacific railroad would service the proposed Millennium Bulk Terminal (MBT) at Longview, WA.
TRAFFIC
Photo courtesy Paul K. Anderson
"Findings have shown that increases in rail traffic have the potential to result in diseconomies as a result of traffic delays," according to a paper taken from a University of Texas Transportation Center study. Recent studies conducted by Gibson Traffic Consultants in the western Washington cities of Seattle, Edmonds, Burlington, Marysville, Mt Vernon, and Stanwood (a study in Bellingham is currently underway) suggest potentially severe consequences due to the proposed increase in rail traffic intensity associated with GPT. Adverse effects include increased risk of accidents, impacts to the city's level of service, decreased ability to provide effective emergency response times, and possible interference with the local freight delivery systems affecting the local economy.
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JOBS and LOCAL BUSINESS
Photo courtesy Paul K. Anderson
There are concerns that diverse existing businesses would be compromised and/or lost in order to accommodate coal traffic. Increased traffic delays at city rail crossings and on I-5, waterfront accessibility issues, and increased noise and pollution would likely all impact local jobs and businesses. Mitigating the disruption to the flow of traffic would require the building of over- and underpasses, which would, themselves, cause disruption to local commerce. It is unclear who would pay for mitigation; these costs are typically borne, in large part, by taxpayers. Rail corridor communities outside of Whatcom County will experience potential negative economic impacts without guarantee of any potential economic benefits (i.e. tax revenue from the terminal, the permanent employment of 44 terminal operators). Ranching and agricultural enterprises can be particularly hard hit by increased rail traffic through their properties and by damages to local water supplies caused by mining. A thorough economic analysis can be conducted as part of the environmental review process.
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Mitigation of Traffic Gridlock:
Attempts to repair the interrupted flow of commerce would likely include the building of over- and underpasses. These mitigation efforts, themselves, would entail physical disruption to and displacement of the surrounding businesses. Projects such as these often take years to complete, and cost many millions of dollars at each site. There are concerns that damages to local business would already be done by the time that such mitigation measures would be completed. As the railroad line is prevented from paying more than a small fraction of total mitigation costs, it seems likely that local residents and businesses would pay, in some part.
Economic Analysis:
There has yet to be a thorough analysis of the economic impacts of the proposed GPT coal terminal, though one could be called for as part of the environmental impact statement. Such an analysis could approximate a net gain or loss of jobs, and a net gain or loss to the economy. It could take into account not only the number of permanent number of jobs created at the terminal site and the tax revenue associated with the terminal, but also job losses, damages to small businesses and fisheries, opportunity costs (such as loss of tourism revenue), and taxpayer expenses for upgraded safety and infrastructure along the rail corridor. It is more difficult to quantify losses to quality of life and regional identity.
Opportunity Costs:
One possible consequence of the project may be to discourage new businesses from locating to the area because of traffic gridlock, loss of quality of life, or diminished attractiveness of waterfront redevelopment projects cut off from the rest of the city due to rail line delays. In Bellingham, for instance, there have been considerable previous investments made in a large waterfront redevelopment project, the impacts of the coal train on the continued development of this project are unknown.
Actual Job Numbers:
There is a great deal of rhetorical confusion about precisely how many jobs will be created and sustained by the Gateway Terminal Project. Peabody and SSA have offered divergent claims about job numbers, ranging from less than a hundred to upward of 4,000, but analysis of the Project Information Document by the Bellingham Herald on May 21, 2011 shows that 89 full-time jobs will be created by the end of the first phase of construction. Then, depending on demand, the number could grow to 160 jobs by 2017 and 213 jobs by 2026. The applicant's traffic impact summary in their land use application to Whatcom County states a maximum of 213 jobs at build-out. Pacific International Terminals/Gateway Pacific Terminal commissioned a study by Martin Associates, and then a review by three local economists. The jobs study and the review were fairly consistent in their findings, projecting the employment of 44 terminal operators at the Cherry Point site. Tug operators, railroad workers, ILWU workers, tug and ship pilots, and maritime services also factored into their 430 "direct jobs" figure.
TAXPAYER INVESTMENT
A recent study conducted by a Billings-based transportation consultant and released by the Western Organization of Resource Councils (WORC) outlines economic costs associated with rail system, road and infrastructure upgrades that would be required by proposed Powder River Basin / West Coast coal export projects. The study indicates that these costs, added to mitigation measures, could total in the billions and would likely be borne by state and local governments. The WORC report complements studies previously released by CommunityWise Bellingham on rail capacity, transportation and economic impact issues. Crosscut offers a concise overview of the situation in an article by Floyd McKay.
READ MORE about Taxpayer Investment
Mitigation refers to the measures taken to diminish the adverse effects of a project. For instance, traffic gridlock at a grade railway crossing can be mitigated by building an overpass or an underpass so that the cars don't have to wait for the train to pass. The building of overpasses at affected railway crossings in Washington State could cost many millions, if not billions, of dollars. Research is currently being done to assess how many critical crossings would require grade separation, and how much this might cost. Building a single grade separation can easily cost 20 million dollars, can cause disruption to neighborhoods if businesses and/or residences need to be condemned or relocated, and can create access problems. There are 24 grade crossings in Whatcom County alone. Additionally, bridges, sidings, and tunnels would need to be built, improved, and/or expanded.
Mitigation costs, by law and by precedent, are normally borne by taxpayers for the building of infrastructure to support additional rail traffic. It is unclear who might pay for any safety measures that might help protect communities from the significantly increased rail traffic. Nothing in SSA's proposal or anything submitted by BNSF suggests a willingness to provide grade separation at all crossings or make other mitigation expenditures necessary to reduce impacts all along the Puget Sound line or along the rest of the rail corridor. BNSF recently cited a "good" example of a community heavily impacted by rail where BNSF paid only 2% of mitigation costs (taxpayers paid the rest). Technically, taxpayer investment in infrastructure necessary to support and mitigate the hauling of coal along the rail line could be considered a public subsidy of a private industry, as the railroads would continue to privately own and control the railways. The profits to be made from transporting and exporting coal would go the the interested parties: SSA Marine, Peabody Energy, BNSF railroad.
Additionally, CommunityWise Bellingham commissioned a study from Transit Safety Management to assess impacts from GPT train traffic on the Bellingham waterfront. The study finds that capacity issues would likely be resolved by additional siding close to downtown, which would impede waterfront access, recreational park use, businesses and future passenger rail service. It is unknown how much taxpayers would be expected to pay for costs and mitigation associated with the siding. Other communities could likewise be affected by rail capacity issues, although studies have not yet been conducted further along the rail corridor.
PROPERTY VALUES
Photo courtesy Paul K. Anderson
Property values could suffer near the coal train corridor. Entrepreneur Magazine found that the worth of small homes near freight rail lines decrease 5-7%.Ranching and agricultural properties are often bisected by rail lines and therefore are particularly affected by increased coal train traffic. The productive value of these properties is further diminished by damages to water supply caused by strip mining in the Powder River Basin. A new study examining Los Angeles neighborhoods supports the notion that home values decrease as nearby rail traffic increases.
MARINE VESSEL TRAFFIC
Photo courtesy Paul K. Anderson
Tens of thousands of marine vessels transit the Strait of Georgia every year, including those destined for the piers of the Alcoa Aluminum smelter, BP and Conoco-Phillips refineries at Cherry Point. Vessel traffic is growing due to a rise in exports and plans for an additional oil pipeline from Canada. The transport of 54 million metric tons per annum (Mtpa) of cargo, 48 Mtpa of which would be coal, from the proposed terminal at Cherry Point, would require the addition of over 900 annual transits (over 450 ships, coming and going) by some of the largest oceangoing vessels. Despite the increase in vessel traffic, Washington's oil response spill program is facing budget cuts. Given the size of vessel involved, a spill of coal and/or oil would be devastating to marine life, shorelines, and Washington's economy.
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The Passage:
Marine vessels in transit to and from the proposed terminal at Cherry Point travel through the Strait of Georgia. The Discovery Islands at the north and San Juan Islands at the south, along with narrow channels, mark each end of the Strait. It adjoins Puget Sound to the south (through Rosario Strait) and the Strait of Juan de Fuca to the west (through Haro Strait).
Cherry Point's deep water trench (about 80 feet) makes it a much sought-after deep water industrial port, as it easily can accommodate Panamax and capesize vessels. This same bathymetrical feature also makes it a vital environmental zone, as the phyto- and zooplankton that form the bottom of the food chain thrive in such a place.
Vessel Size/Type, Projected Number of Transits:
The Strait of Georgia is one of the busiest shipping lanes in the world and is getting busier with recent increases in the region's marine exports. In addition, the number of oil tankers traveling from Canada through the Strait of Georgia has increased dramatically due to an increased volume of oil exports. Moreover, the number of oil tankers and the volume of oil exports in the Strait are expected to grow unprecedentedly high with North America's Kinder Morgan energy company's plans to proceed with a major oil pipeline expansion linking Alberta tar sands oil to Vancouver's Westridge terminal.
Cherry Point's eight mile shoreline currently receives 850 annual transits from its three existing marine piers. The proposed terminal would add approximately 221-487 (by 2026) vessels for a total of 442-947 transits per year. Vessels will be either Panamax or Capesize. Panamax class are the largest vessels that can cargo through the Panama Canal, they are up to 950 feet long by 106 feet wide, with a deadweight of 50,000 – 80,000 tonnes . Capesize vessels are too wide to fit through the Panama or Suez Canal and therefore must travel around the Cape of Good Hope or Cape Horn. These vessels require deep-water ports and can carry a deadweight of 80,001 to 199,000 tonnes (which would include both bulk commodity i.e. coal and ballast water for stability).
Vessel Collision, Groundings and Delays:
A 2008 BP Refinery Vessel Traffic Risk Assessment study projected dramatic increases for both the risk of marine vessel accidents and oil spills or outflows resulting from collisions between two vessels, groundings (both powered and drift), and allisions (collisions with the dock or other fixed objects) if crude vessel traffic levels increased by 17% at the BP Cherry Point Refinery.
A review of the environmental and safety documents for the initial (1997) proposed Gateway Pacific Terminal, shows that the proposed increase in vessels would result in an increase of approximately 60% in the deep draft ship traffic in the upper Rosario Strait, the route most vessels from the terminal would likely take. The review also found that the increase in proposed deep draft traffic on the risk of collisions and powered vessel groundings in Rosario Strait was not adequately addressed by the 1997 Vessel Traffic Study. Collision frequency is highly dependent upon traffic density and environmental conditions. Vessels most likely to be involved in a collision with a large bulk cargo vessel are: passenger ferries, tank barges, and tank vessels—the impact of which any one would be catastrophic. Powered or drift groundings of large bulk carriers are also a serious risk given that they carry thousands of tons of bunkers in single bottom tanks and they are not escorted by tugs. Marine traffic delays and backups in the Rosario Strait will also likely occur given that it is a one-way zone for deep draft vessels.
Air Pollution from Marine Vessels:
Marine vessels represent one of the most difficult to regulate sources of air pollution in the world. Sometimes called "floating power plants," marine vessels emit sufficient pollutants to negatively impact the air quality and health of people near ports and inland waterways. Marine vessels used in international shipping are typically powered by diesel engines fueled by either diesel (distillate) or residual fuel. Diesel engines generate significant amounts of fine particle and toxic emissions, which are linked to cancer, cardiovascular problems, aggravated asthma, chronic bronchitis and premature death. Additionally, in response to increasing oil prices and the large quantities of fuel needed to operate vessels, lower quality residual fuel called bunker fuel is commonly used. Bunker fuel has a very high sulfur content which, when burned, emits harmful levels of particulate matter and nitrogen oxide that can travel inland, causing severe respiratory illnesses. Airborne pollution at Cherry Point is primarily from marine vessel traffic and stationary sources. Marine vessels account for the largest single source of sulfur dioxide in the airshed in the larger Georgia Basin (where the Cherry Point Aquatic Reserve is located).
MARINE IMPACTS
Cartographer: Stefan Freelan
Sharply increased marine traffic, physical disruption of ecologically sensitive areas, and open coal storage in proximity to the Cherry Point Aquatic Reserve give rise to concerns about the proposed coal export facility. The risk of collisions and oil spills rises as coal ships are added to waters already crowded with oil tankers. 80-100 acres ofopen coal heaps will be in proximity to the aquatic reserve, in an area sometimes subjected to high winds; it is unknown to what extent coal dust in the water might affect the marine plants and animals. The construction of the facility and rail loops on wetlands and uplands, and of the wharf and trestle area over the water, have the potential to disrupt fragile ecosystems. Cherry Point herringare a keystone species, providing food for a number of other species; their status is currently fragile, and would likely be further stressed by activities associated with the coal port. Increasednoise pollution, increased risk of collision with marine vessels, threatened food sources (i.e. herring), and a degraded marine environment would pose challenges to killer whales, salmon and a myriad of shore and migratory bird populations. Ballast water carried from Asian ports and released into local waters could introduce invasive species, to possibly devastating consequence.
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Oil Spill Risks:
Tens of thousands of marine vessels transit the Strait of Georgia every year, including those destined for Cherry Point. The Strait of Georgia has been designated by Parks Canada as Canada's "most-at-risk natural environment." Vessel traffic is growing due to a rise in exports and plans for a major oil pipeline expansion in Canada. Coal transport from the proposed terminal at Cherry Point would require, at build-out, an additional 974 annual transits by some of the largest oceangoing vessels. Despite the increase in vessel traffic and a Vessel Traffic Risk Assessment correlating higher vessel traffic levels with a higher risk of accidents and oil spills, Washington's oil spill response program is facing budget cuts. Effects from collision or grounding are amplified by the type of vessel and cargo; oil and/or coal would be devastating to marine life, shorelines, and Washington's economy in the event of a spill.
The Risks to Cherry Point Herring:
Washington herring are a keystone species, as they provide food for a number of other species. Cherry Point herring, unlike other regional herring populations that spawn at sea in the winter, migrate toward fresh water and estuaries to spawn in the spring. This unique spawning schedule and location makes the Cherry Point herring a vital source of food for endangered Chinook salmon. The Chinook salmon, in turn, provide sustenance for orca/killer whales, porpoises and other marine mammals. Cherry Point herring was once the most abundant herring species in Washington state waters; their population has declined by over 90%. Efforts to have this critical and fragile species declared "endangered" have so far been unsuccessful.
Noise and vessel movement are stressors to Pacific herring. The waters at Cherry Point serve as a "core" region for Pacific herring spawn deposition. Because Cherry Point herring spawn in open, high energy shoreline areas, vessels in transit to and from the proposed Terminal could cross through their prespawning holding areas and disrupt their spawning habits. According to Washington Fish and Wildlife, conservation of herring spawning habitat and minimizing disturbance in the prespawning holding areas are key to preservation of herring stock inside Puget Sound. Additionally, shading from the proposed Terminal's wharf and trestle could further decrease the herring population by causing a decline in herring spawning habitat and primary productivity due to reduction of macroalgae. Coal dust, which is notoriously difficult to control, blowing or running into the water from the proposed Terminal's uncovered 80-acre coal storage area could further shade critical macroalgae or seagrass species and deplete critical oxygen in nearshore habitats. Noting the regional importance of the Cherry Point herring stock, the WDNR, in a 1998 letter to Pacific International Terminals, stated that further herring studies and a regional risk analysis were necessary and that it would "allow the construction of the Terminal only if the completed regional ecological risk analysis shows that construction and operation activities will not pose an unacceptable risk to the Cherry Point herring stock."
Killer Whales (Orca) and other Marine Mammals:
Marine mammals in and around the waters at the proposed Terminal may be injured or killed by collision with vessels. Disturbance by marine traffic from noise and vessel movement, reduction of food (Chinook salmon, herring, cod), and high levels of environmental contaminants are the three main factors causing the decline of threatened Northern Resident and endangered Southern Resident Killer Whales.
Cherry Point Habitats:
The Cherry Point Aquatic Reserve encompasses important habitats, including those of mixed microalgae (critical for salmon and herring), kelp, eelgrass beds, a salt marsh, and two small freshwater streams, which provide lower salinity in the nearshore, which in turn provides habitat for many fish species, including Pacific herring, salmon, surf smelt, and groundfish. Surf smelt spawning very high up in the tideland area rely on the beach's mix of sand and fine gravel. The Reserve is listed as a significant bird habitat, and its wetland supports many species of marine and migratory birds. Marine mammals that may use the Reserve's waters include: Dall's porpoise, Stellar and California sea lions, gray whales, harbor seals, Southern Resident Killer Whales, humpback whales, seals, and Pacific harbor porpoise.
The Importance of Wetlands at Cherry Point:
A wetland impact assessment of the proposed project at Cherry Point has determined direct permanent wetland impacts to approximately 140.6 acres of wetlands, including filling and grading or cutting to raise areas for rail embankments. The project will be located within two coastal watersheds—the Gateway Pacific Terminal Watershed and the Birch Bay Watershed, which contains extensive wetlands associated with Terrell Creek and Lake Terrell, including a 1,500-acre wildlife area managed by the Washington Department of Fish and Wildlife (WDFW) for wintering waterfowl (Canada geese, duck, trumpeter and tundra swans, pheasants). In addition, Lake Terrell wetlands support the second largest heron rookery in Washington. Indirect effects to aquatic systems downstream are expected as well. Potential negative changes to stormwater; soil erosion and sedimentation; and spills and fugitive coal dust all would degrade water quality.
Ballast Water and the Risk of Invasive Species:
In order to maintain stability and structural strength during transit, cargo vessels fill their ballast tanks with water at one port and then discharge it at another when receiving cargo. A single modern cargo vessel can carry anywhere from 100,000 to 10 million gallons or more of ballast water (6 million gallons is approximately 10 Olympic-size swimming pools) — all potentially containing several hundred different invasive aquatic species (plants, insects, animals, microbes). Once established, the invasive species can become a significant threat to biodiversity because there are often no natural predators to control them. The introduction of invasive marine species into new environments by ships' ballast water has been identified by the United Nations as one of the four greatest threats to the world's oceans. The International Maritime Organization (IMO) recommends guidelines to minimize the risk of spreading aquatic nuisance species such as mid-ocean water exchange of ballast water. Several countries have adopted the IMO standards. However, in the United States, the US Coast Guard (USCG) has yet to mandate a ballast water discharge standard to help vessel operators comply with its ballast water management practices.
The Cherry Point Aquatic Reserve & Required Environmental Protection:
Because part of the proposed terminal (the wharf and nearly all the trestle) will need to be built on state-owned tidelands, a lease from the Washington Department of Natural Resources (WDNR) is required. These tidelands have been recognized by the State of Washington as part of the Cherry Point Aquatic Reserve. In 2010, the WDNR adopted a Management Plan to assist in its management and protection of the Reserve. The Management Plan identifies environmental protection of the Reserve over and above all other management actions. In addition to following the Management Plan, it is also the responsibility of the WDNR, under state law, to withhold from leasing lands which it finds to have significant natural values.
GPT and the Aquatic Reserve: concerns and incomplete studies:
While there are many effects to consider regarding the proposed terminal and increase in marine traffic, several key areas of concern were identified by environmental groups and state agencies during negotiations to a 1999 Settlement Agreement between Pacific International Terminals, Inc. and five citizen groups, including: "impacts to habitat in the footprint of the pier from shading and ship operations; impacts to herring, particularly during spawning season; ballast water exchange; water quality deterioration from construction and operation of the facility; vessel traffic impacts; public access issues, and questions surrounding how many additional piers will be allowed…." As key conditions of the settlement, Pacific International Terminals, Inc. agreed to conduct and fund mitigation and monitoring programs for macroalgae, herring, ballast water, sediment, as well as a vessel traffic analysis, which will evaluate impacts of increased vessel traffic, oil spill risk, hazards at the facility, and bunkering (fueling) operations. Many of these studies have yet to be completed. Additionally, a Biological Assesment (in preparation) will evaluate impacts on marine habitat, threatened, endangered, and priority species, including salmon and herring.
FISHERIES
Partly due to its deep water feature, Cherry Point has been an especially rich and fertile marine area. The waters around Cherry Point have traditionally been part of abundant salmon and lingcod fisheries. There has also been a vigorous recreational, commercial, and tribal Dungeness crab fishery. Damages to the local herring population would result in damages to the salmon and lingcod fisheries, as herring are a primary source of nutrition for these fish. Heavily increased marine traffic could result in losses both the fisheries and the fisherman, as crabbing gear can be destroyed or carried away by large marine vessels.
READ MORE about Fisheries
Herring Populations, Eelgrass Beds and Fisheries:
According to the Cherry Point Aquatic Reserve Management Plan, there are several factors that could disturb the already fragile herring population. Light, noise, shading, and movement from the terminal and/or from marine vessels could disrupt herring spawning. Many fish, mammals, and aquatic birds are dependent upon herring, including: Pacific Cod, Lingcod, halibut, Chinook salmon, harbor seals, herons, western grebes, common murres, rhinoceros auklets, tufted puffins, orcas, seals, sea lions, Dall's porpoises and surf scoters.
The Department of Natural Resources (DNR) has extensively studied the Cherry Point herring population and its decline. Their website contains a study called "Covered Species Paper" that documents the health of the Cherry Point Pacific herring population (see pps. 3-80 through 3-87). Two state agencies, Puget Sound Partnership (PSP) and DNR, have been studying eelgrass in the Puget Sound because it is a preferred habitat for herring spawn deposition. PSP has just adopted "Recovery Targets" for Puget Sound eelgrass. DNR's Nearshore Habitat Program webpage includes scientific studies on eelgrass, including a paper entitled "Developing Indicators and Targets for Eelgrass in Puget Sound." PSP has generated numerous scientific documents relating to the health of the Puget Sound generally, including the 2009 State of the Sound Report. It has also published specific recovery targets for protecting and restoring eelgrass habitat: "Eelgrass extent in 2020 is 120 percent of area measured in the 2000-2008 baseline period."
Much has been written about the decline of anadromous fisheries in the Puget Sound. Anadromous fish are those that are born in fresh water, live their lives in salt water, then return to fresh water to spawn. Salmon and smelt are examples. The importance of estuaries in marine life can not be overstated; a healthy estuarial system is critical to the survival of certain species. DNR has done a study on threatened and covered species listed under the Endangered Species Act (ESA) as a part of its "Aquatic Lands Habitat Conservation Plan." You can also see the National Marine Fisheries Service website, which administers the ESA and recovery planning for listed species.
The federal government, the Puget Sound Partnership, and the state DNR have invested millions of dollars in working to restore marine ecologies that now may be jeopardized by the substantial increase in ship traffic, pollution and wetland disturbance associated with the proposed coal port site.
QUALITY OF LIFE and REGIONAL IDENTITY
The Northwest is a region noted for spectacular physical beauty, an emphasis on "quality of life," and a dedication to clean, healthy living and environmental stewardship. It is considered a prime tourist destination spot and a highly desirable place to live; it is both agriculturally rich and a haven for innovative business. The pollution, traffic, noise, and degradation of our waters and fisheries that would come with significant coal train and ship traffic is at odds with our enjoyment and stewardship of this region. Choosing to become an economy in which coal transport is an emphasis seemingly undermines aspirations to build on the Northwest economies of tourism, healthy agriculture, innovative businesses, clean energy and the manufacture of local goods. Even our icons – the salmon and the orca– would be imperiled by the proposed project. The Northwest's most valuable asset is our quality of life –witness the profusion of Northwest communities on "best places" lists– and this quality is what hangs in the balance.
READ MORE about Quality of Life and Regional Identity
Along the Puget Sound rail corridor, many communities have invested in the transformation of waterfront from industrial to commercial use as an essential part of a plan for sustainable economic viability. A continuously in-use train track effectively shears such a town off from its waterfront, and jeopardizes such long-term planning. For example, according to a study conducted by CommunityWise Bellingham, Bellingham's waterfront Boulevard Park and Taylor Street Dock could be cut off entirely from vehicular access by the addition of coal train rail siding.
The transport of another region's goods to another country brings limited benefit to our region, at significant cost to our region. In particular, many feel that the export of a highly polluting form of fossil fuel is contradictory to this region's values and dedication to phase out domestic coal-burning power plants. The Puget Sound Partnership compiled an action agenda which addresses many of these quality of life concerns.
COAL DUST
Photo courtesy Paul K. Anderson
Coal dust is notoriously difficult to control. BNSF estimates that each uncovered car loses between 500 pounds and a ton of coal dust en route. It is unknown how much coal dust will be released into the air, onto the land, and into the water from the from the 80-100+ acres of open, continuously turned-over, coal heaps in storage at the terminal site. There are concerns about train derailments, the effects of dust on human health, local clean water supplies, and on the marine environment. The methods of containing coal dust, especially in adverse weather conditions (wind, rain) are unproven, and it is uncertain which party would pay for dust mitigation measures.
READ MORE about Coal Dust
Because most coal trains are uncovered, they produce significant amounts of coal dust in the course of transporting the coal from one place to another. According to BNSF research, 500 pounds to a ton of of coal can escape a single loaded car. Coal dust is regarded as a nuisance, as the dust can damage the ballast and, the railway claims, cause derailments. BNSF asks that shippers pay for dust mitigation; shippers typically balk at paying. The Puget Sound coast line is notoriously rainy and windy; it is unclear as to how effective surfactants might be at containing the pulverized coal in adverse weather. There seem to be no guarantees that dust would successfully be controlled en route from the mines to the port.
Dust is also generated at the terminal site, as bulldozers continually shift and rotate the ground-up coal. Constant turnover is required to both keep the coal in one area, and also to prevent spontaneous combustion. Wind and moisture can agitate the combustive properties of coal. The potential adverse effects of coal dust on adjacent sites was a factor in the Port of Vancouver rejecting a proposal to export coal from a new export site there. The dust is notoriously difficult to control, and has proven to be a concern for residents close to Westshore, the coal port in BC. The coal at the proposed GPT terminal will be stored in open heaps on 80-105 acres located in proximity to the Cherry Point Aquatic Reserve. Cherry Point can be buffeted by high winds, winter conditions often see wind gusts in the 60-70 knot range. It seems likely that the wind will agitate the heaped, pulverized coal.
The leaching of toxic heavy metals from coal ash into water supplies is a proven problem. Exposure to arsenic, cadmium, barium, chromium, selenium, lead and mercury can cause any number of health problems, including cancers and neurological diseases. It is unknown if and to what extent these heavy metals might leach out from the coal and/or fugitive coal dust, from the train cars and at the terminal storage site, into local water supplies and into the marine environment. There are potential implications for the safety of the water we drink and the seafood we eat.
COAL TRAIN DERAILMENTS
- Burleson County, TX – August 2013
- Rushville, MO – July 2013
- Albermarle, VA – July 2013
- Calgary, AB – June 2013
- De Soto, IL – June 2013
- Peoria, IL – May 2013
- Grand Junction, IA – May 2013
- Bridgeport, NE – April 2013
- Fremont, NE – April 2013
- Kenner, LA – March 2013
- Saginaw, MI – March 2013
- Nashua, NH – March 2013
- Swartz, LA – March 2013
- Missoula, MT – March 2013
- Sterling, CO – March 2013
- Lilbourn, MO – February 2013
- Bloomington, MD – February 2013
- Gore, WV – February 2013
- Aberdeen, SD – February 2013
- St. Charles, VA – December 2012
- Grantville, KS – November 2012
- Painstville, KY – November 2012
- Ashby, NE – October 2012
- Oktaha, OK – September 2012
- Ellicott City, MD – August 2012
- Grants, NM – August 2012
- Raleigh, WV – August 2012
- Saline County, KS – July 2012
- Havelock, NC – July 2012
- Jefferson County, KS – July 2012
- Princeton, IN – July 2012
- Pendleton, TX – July 2012
- Northbrook/Glenview, IL – July 2012
- Mesa, WA – July 2012
- Portageville, MO – June 2012
- Junction City, KS – June 2012
- Collins, MS – May 2012
- Salmon Arm, BC – April 2012
- Houston, BC – February 2012
- Hinton, Alberta – January 2012
- Vanderhoof, BC – January 2012
- Montrose, IA – December 2011
- Vanderhoof, BC – December 2011
- Galland, BC – December 2011
- Topeka, KS – November 2011
- Peetz, NE – October 2011
- Charleston, WV – October 2011
- Emmett, KS – September 2011
- Denison, IA – July 2011
- Omaha, NE – July 2011
- Bloomington, IN – July 2011
- Ashdown, AK – July 2011
- Pueblo, CO – November 2010
- Surveyor, WV – April 2011
- Kearney, NE – September 2010
- Quantico, VA – August 2010
- Drummond, MT – August 2010
- Ferry Farm, VA – July 2010
And, a 2006 spill that resulted in 2 loaded cars being submerged in the Clark Ford River:
- Trout Creek, MT – November 2006, 2-4 cars spilled and submerged into Clark Fork River – resulting in EPA Superfund action.
AIR QUALITY
Pollutants, weather, wind patterns and topography all affect local air quality. Accurately predicting the effects of the Gateway Pacific Terminal on the air we breathe, and thus on public health, will require much good science. Both the means of transporting coal and the coal itself present potential air quality challenges. Diesel particulate matter emitted by the coal trains and ships; fugitive coal dust from the trains and from storage at the port site; and the toxins that blow over the Pacific to the West Coast of the US from coal combustion in Asia, are all cause for concern with regard to regional air quality and the resultant health effect on humans who breathe that air.
READ MORE about Air Quality
BNSF has indicated that each coal car loses 500 lbs to a ton of coal dust en route; 80 near shore acres at the GPT terminal site would be covered in open heaps of coal. Newspaper photos of coal dust over two relatively small British Columbia coal ports, one at Westshore and one at Ridley would seem to indicate that dust management, as currently practiced, is not effective. While coal dust is a reported nuisance in coal port communities, the health effects of pulverized coal released into the air have not yet, to our knowledge, been systematically studied. Coal dust inhalation in closed situations is, of course, a different matter, although instructive in the kind of governmental oversight and corporate compliance that is necessary to keep people safe: NPR and the Center for Public Integrity recently reported the resurgence of black lung disease in American miners is due to "weak regulation and industry deception."
It is worth considering that our air is directly affected by what happens in Asia, the market to which GPT would ship coal. The Jaffe Group has proven that mercury emitted by coal combustion in Asia crosses over the Pacific Ocean and pollutes our Northwest water supplies; mercury is implicated in a number of health problems, especially those involving the brain and nervous system. The New York Times has written that sulphur dioxide, which can cause respiratory disorders, likewise blows back to us from Asia. Noted meteorologist and UW atmospheric scientist Cliff Mass has shown that the haze over much of the Pacific Northwest coastline in early summer 2012 was smoke from massive Asian wildfires. What burns in Asia does not stay in Asia: we all breathe the same air.
NOISE
While there are many sources of noise from trains (high-pitch screeching, idling engines; moving cars, etc.), horn sounding is the most significant. Federal rules governing the blowing of locomotive engine horns require that engineers of all trains sound horns for at least 15-20 seconds at 96-110 decibels (dB) at all public crossings. Decibels in the range of 80-105 are labeled extremely loud, whereas those above 105 are dangerous. Decibels are logarithmic, meaning that 100 decibels is ten times as loud as 90, 110 decibels is ten times as loud as 100, and so on. While impacts to quality of life from repeated loud noise are self-evident, chronic noise exposure has proven adverse health effects, including impaired sleep and cognitive function, and cardiovascular effects.
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The Federal Railroad Administration (FRA), regulates the sounding of train horns at public highway railroad at-grade crossings i.e. where a public roadway crosses the railroad tracks at the same level. Under the train horn rule, the FRA requires train horns to be at least 96 dB and no louder than 110 dB. Since sound propagates depending on conditions like weather, openness of land, etc., only someone standing right next to the train hears the horns at 96-110 dB levels. Using the inverse square law, an estimate of someone living within 300 feet of the rail can be predicted to hear a train horn of 110 dB at 70.77 dB, which is categorized as very loud.
With few exceptions, before reaching an at-grade crossing, the FRA requires a locomotive engineer to sound the horn in a pattern: 2 long: 1 short: 1 long for a minimum of 15 second and a maximum of 20 seconds.
An Example of Potential Noise Increases:
There are 12 at-grade public crossings within the City of Bellingham. Current train traffic through Bellingham is estimated at 12-15 trains per day, accounting for at least 36 minutes of horn noise (15-second soundings x 12 at-grade crossings x 12 existing trains = 2,160 seconds). An additional 18 trains per day will add 54 minutes of horn soundings: (15-second soundings x 12 at-grade crossings x 18 trains = 3,240 seconds) for a total of 90 minutes. Each day, this 90 minutes will be comprised of at least 1440 horn blows (4 x 12 at-grade crossings x 30 trains).
Adverse Health Impacts from Noise:
Studies on noise from aircraft, roadways, and trains show that continuous noise above 30 dB or frequent intermittent noise disturbs sleep. In addition to sleep disturbance, noise during sleep causes increased blood pressure, increased heart rate, increased pulse amplitude, vasoconstriction, changes in respiration, cardiac arrhythmias, and increased body movement.
Secondary effects from sleep disturbance can also occur including fatigue, depressed mood and well-being, and decreased performance and alertness. Cardiovascular effects, independent of sleep disturbance, can also occur with acute exposure to noise mostly due to elevated blood pressures and levels of stress-induced hormones. In addition, noise can exacerbate stress and anxiety and impair task performance. The National Institute for Occupational Safety and Health recommends less than 15 minutes of exposure per day to noises over 100dB.
Noise Mitigation:
To mitigate train noise, some cities have established quiet zones, in which safety modifications are made to public crossings; exempting trains from their horn soundings at the modified crossing. However, the high cost of significant improvements at public crossings borne by cities and taxpayers has been a deterrent. Moreover, once a crossing is converted into a quiet zone, liability shifts from the railroad to the city for any traffic or personal injury incurred within the quiet zone.
PUBLIC HEALTH
Frequent long trains at rail crossings will mean delayed emergency medical service response times, as well as increased risk of accidents, traumatic injury and death.
The scale of the proposed terminal would require a dramatic increase in the number of diesel-burning locomotives and marine vessels affecting Puget Sound airsheds. Diesel particulate matter is a particularly noxious form of air pollution, as it is of sufficiently small size (PM 2.5) to embed in the lung tissue. Diesel particulate matter is associated with both pulmonary and cardiovascular issues, including cancers, heart disease, and asthma. Children, teens and the elderly are especially vulnerable. Noise exposure can cause cardiovascular disease; cognitive impairment in children; sleep disturbance and resultant fatigue; hypertension; arrhythmia; and increased rate of accidents and injuries; and exacerbation of mental health disorders such as depression, stress and anxiety, and psychosis. Transporting coal to China in particular has the potential to raise levels of mercury in our waters. Mercury is associated with neurological dysfunction, as in ALS, Parkinson's, and Alzheimer's.
READ MORE about Health Concerns
For further explanation of public health concerns, please see the Physicians' Position Statement calling for a Health Impact Assessment. The attached appendices go into further detail about: pulmonary, cardiovascular, coal dust, noise exposure, and delayed emergency vehicle response time concerns.
Whatcom Docs, a group representing over 180 local physicians, and an increasing number of health care providers from the Pacific Northwest (Skagit, King and Thurston counties; Oregon) are calling for a Health Impact Assessment (HIA). While few specific mandates or resources exist for conducting HIA, its use is increasing and recently has been included in state legislation to fulfill regulatory requirements. For example, Washington state required an HIA be performed to inform mitigation planning for the State Route 520 Bridge in Seattle to analyze effects on air pollution exposure. Realizing the benefits of HIA, many are advocating its analysis be integrated with or part of the Environmental Impact Assessment process.
For more information on HIAs:
- Center for Disease Control Fact Sheet on Health Impact Assessments
- A Guide for Health Impact Assessment
- Health Impact Project: About the HIA
- Health Impact Project: The HIA Process
- Public Health – Seattle and King County Health Impact Assessment
Many people have expressed anxiety about coal dust. Although coal dust contains toxic heavy metals and has been associated with emphysema, chronic bronchitis, and malignancy in people who work closely with coal in mining, processing and/or transport, it is not yet known what, if any, health effects fugitive coal dust from coal trains or from the uncovered coal heaps in storage, might have on the general population. A more pressing question might involve the effects of coal dust from the trains and/or storage site leaching into local water supplies, about which little is known.
GLOBAL IMPACTS
While the Gateway Pacific Terminal and the associated coal trains would be active in only the transport and export of coal, it is important to recognize that the only function of coal transport is to link coal mining to coal combustion: GPT and related enterprises need to be considered as part of this larger system. Each of the various processes associated with coal have negative effects on local economies, public health, communities and the environment. The coal mines in the Powder River Basin (Montana and Wyoming) continue to degrade local aquifers and water supplies. Coal combustion in China presents a serious health risk to the hundreds of millions of people, especially children, who live in affected airsheds. Coal combustion is also associated with negative impacts that transcend geographic borders. Ocean acidification, acid rain, mercury emissions, and climate change affect global populations, regardless of where the coal is burned. The financial cost accrued from health and environmental damages from coal mining, processing, transport and combustion are currently estimated at a third to over half a trillion dollars annually in the U.S. alone.
READ MORE about Global Impacts
China, PRB Coal, and the Global Energy Market:
We are at a critical time and a critical place: a West Coast coal export industry of the scale currently under discussion could influence Chinese energy policy for the next half-century: increasing the supply of cheap coal could reduce the incentive to pursue clean energy. While regulations such as The Clean Air Act have limited the profitability of coal in the U.S. and provided a degree of environmental and health protection, China has no such regulations.
From 2005 to 2030 the global demand for electricity is expected to double, bringing with it an increase in coal consumption. Although the U.S. Energy Information Administration predicts that by 2030 nearly 90% of increased coal consumption will be attributed to China, this prediction is not inevitable. Economic analysis shows that Chinese demand is sensitive to the value of coal in the market place. Recently an empirical study performed in China found that a 10 percent decrease in the cost of coal resulted in a 12 percent increase in Chinese coal consumption.
The proposed Gateway Pacific Terminal is part of a larger trend to create a coal export industry in the United States. SSA Marine at Cherry Point and Millennium Bulk Terminals at Longview are currently seeking permits that would allow them to export close to 110 million tons of coal annually. In addition, Port of Morrow in eastern Oregon has signed a one-year lease to transfer coal, while other ports, including Port of St. Helens, Coos Bay, and Grays Harbor, are also being considered.
In order to profit, Washington ports will have to undercut the prices of Australian and Asian competitors as well as other North American sources. Increased competition results in reduced price. Inserting Powder River Basin (PRB) coal into the global market each year could influence China towards a future of coal and away from exploring renewables.
Quantifying the Effects of Coal Mining, Transport, Processing and Combustion:
While certain parties stand to profit considerably from coal, the general population will suffer economic loss due to its health and environmental impacts. Studies quantifying such comprehensive costs include that of Dr. Paul Epstein of the Harvard Medical School Center for Health and the Global Environment. A 2011 study co-authored with 11 peers traces each stage in the life cycle of coal. As the report states, "Each stage—extraction, transport, processing, and combustion—generates a waste stream and carries multiple hazards for health and the environment." These effects are defined as "externalities." Coal companies are not responsible for these costs. Rather, they fall to the public. The Epstein study estimates that each year externalities cost the U.S. public a third to over $500 billion or half a trillion dollars.
Externalities transcend borders. The effects of air pollution, mercury emissions, acid precipitation, ocean acidification and climate change are felt globally regardless of where the coal is burned.
Public Health: At home and in China:
Coal combustion produces sulfur dioxide, which causes the premature deaths of about 400,000 people in China each year. Pollution from coal combustion makes some cities so dark that people drive with their lights on during the day. Some of that sulfur dioxide pollution crosses the Pacific Ocean, and has been detected in California, Oregon and Washington State. India, whose population is expected to exceed China's by 2030, is accelerating construction of coal-burning plants.
Acid Rain:
Another externality of coal combustion is acid precipitation or acid rain. The primary man-made cause of acid rain is sulfur dioxide (SO2) and nitrogen oxides (NOx), released from burning fossil fuels like coal. Approximately 2/3 of all SO2 and ¼ of all NOx in the U.S. comes from burning fossil fuels for power. Acid rain is not limited to national borders and can travel hundreds of miles before precipitation occurs. Although the U.S. has taken action to regulate coal power plants domestically and thus reduce acid rain, these efforts would be undermined from a global perspective if U.S. coal contributes to Chinese acidification—a form of pollution that already effects not only China, but threatens quality of life across the Pacific Rim, resulting in increased illness and premature death from heart and lung disorders, such as asthma and bronchitis.
Mercury:
While acid rain can travel hundreds of miles, mercury emissions can travel thousands of miles. The EPA estimates that 34% of mercury emissions in the U.S. come from non-U.S. sources. In Oregon, a researcher estimated that 18% of mercury in the Willamete River came from overseas. Increasingly the source of mercury is Asia. From 1990 to 1995, Asia's contribution to the global inventory rose from 30 to 56%. Like acid rain, coal burning power plants are the primary cause of mercury. After mercury from coal combustion is emitted into the atmosphere, it settles in water, where microorganisms change it to methylmercury, a high toxic chemical that builds up in shellfish and fish. Human consumption of methylmercury infected seafood can harm the brain, heart, kidneys, lungs and immune system. For pregnant woman, methylmercury exposure can damage the nervous system of unborn children resulting in mental retardation. A 2003 study conducted by the Centers for Disease Control and Prevention found that one in twelve women (8%) of childbearing age had mercury in their blood above levels deemed safe by the EPA.
Ocean Acidification:
The burning of fossil fuels, including coal, release carbon dioxide into the atmosphere. About a quarter of all carbon dioxide emissions are absorbed into the world's oceans. This carbon dioxide changes the chemistry of the ocean water, making it more acidic. Marine life has been and is being harmed by this rather sudden and dramatic change; the ocean's pH had remained fairly stable for about 20 million years prior to humans burning coal and oil. At current rates, the waters around Antartica will become corrosive by 2050. High acidity will fundamentally alter the nature of the oceans and any human connection (fishing, tourism, recreation) with them.
A recent study published in the journal Limnology and Oceanography shows that ocean acidification is occurring much sooner than predicted. Since 2005, oyster farms and hatcheries in the Pacific Northwest have been experiencing massive oyster larvae die-offs during periods of ocean upwelling. During these periods, scientists have determined that the level of acidity from the combination of more acidic deep ocean water from the upwell and the rising carbon dioxide levels in surface water from increased CO2 emissions is too high for the oyster larvae to survive.
Climate Change:
Of the greenhouse gases linked to global warming, the UN's Intergovernmental Panel on Climate Change (IPCC) cites carbon dioxide as being the single most important. Coal burning is the primary contributor of CO2 emissions, accounting for 81% of emissions in the U.S. Overall coal combustion contributes at least one-third of heat trapping chemicals. Carbon emissions have already shown an alarming increase, rising 80% from 1970 to 2004.
West coal export would contribute to this trend, allowing for close to 110 million tons of Powder River Basin coal to leave Washington annually. For context, burning this amount of PRB coal is roughly equivalent to the annual carbon emissions of 40 million cars. For every 100 million tons of PRB coal burned, 180 million tons of heat trapping carbon-dioxide are released into the atmosphere. That constitutes twice the greenhouse gas emissions of the entire state of Washington, including every power plant, car, truck factory, and farm combined.
The IPCC report states that in order for the global temperature to stabilize between 2 and 2.4 degrees above the pre-industrial average, emissions would need to peak before 2015. Rather than peaking, coal exporters hope to hit their stride in 2015, abandoning the IPCC warnings in order to take advantage of a market that Peabody Energy estimates will have grown to 220-260 million metric tons a year by that time.
Economics of Climate Change:
To date, the most comprehensive study done to measure the full economic effect of climate change is the Stern Review, a 700 page independent report released for the British government led by Sir Nicholas Stern of The Grantham Research Institute on Climate Change and the Environment.
At current rates, the stock of greenhouse gases in the atmosphere would reach 550ppm CO2e by 2050, doubling pre-industrial averages. However increasing transportation and energy demand has resulted in an acceleration of emissions. The level of 550ppm CO2e could be reached as early as 2035. Depending on the climate model used, there is a 77% to 99% chance that at this level global warming will rise 2 degrees Celsius. If emissions go uncurbed, the study estimates a 50% risk of exceeding 5° C global temperature rise in the decades following the turn of the century.
The economic effect of climate change is proportional to the rise in temperature. Today the world has warmed half a degree Celsius, and already seen a measured increase in asthma, heat waves, clusters of illnesses after heavy rain events and intense storms, and the distribution of infectious disease. The costs of weather-related disasters rose 10-fold from the 1980s to the 1990s (from an average of $4 billion/year to $40 billion/year) and jumped again in the past decade, reaching $225 billion in 2005.
Effect of Uncurbed Emissions:
Given that current trends anticipate a 2-3° C warming over the next fifty years or so—a number that will rise several more degrees if emissions continue to grow—the Stern Review reveals the following severe impacts:
- "Melting glaciers will initially increase flood risk and then strongly reduce water supplies, eventually threatening one-sixth of the world's population, predominantly in the Indian sub-continent, parts of China, and the Andes in South America."
- "Declining crop yields, especially in Africa, could leave hundreds of millions without the ability to produce or purchase sufficient food. At mid to high latitudes, crop yields may increase for moderate temperature rises (2 – 3°C), but then decline with greater amounts of warming. At 4°C and above, global food production is likely to be seriously affected."
- "In higher latitudes, cold-related deaths will decrease. But climate change will increase worldwide deaths from malnutrition and heat stress. Vector-borne diseases such as malaria and dengue fever could become more widespread if effective control measures are not in place."
- "Rising sea levels will result in tens to hundreds of millions more people flooded each year with warming of 3 or 4°C. There will be serious risks and increasing pressures for coastal protection in South East Asia (Bangladesh and Vietnam), small islands in the Caribbean and the Pacific, and large coastal cities, such as Tokyo, New York, Cairo and London. According to one estimate, by the middle of the century, 200 million people may become permanently displaced due to rising sea levels, heavier floods, and more intense droughts."
- "Ecosystems will be particularly vulnerable to climate change, with around 15 – 40% of species potentially facing extinction after only 2°C of warming. And ocean acidification, a direct result of rising carbon dioxide levels, will have major effects on marine ecosystems, with possible adverse consequences on fish stocks."
- "Warming may induce sudden shifts in regional weather patterns such as the monsoon rains in South Asia or the El Niño phenomenon – changes that would have severe consequences for water availability and flooding in tropical regions and threaten the livelihoods of millions of people."
- "A number of studies suggest that the Amazon rainforest could be vulnerable to climate change, with models projecting significant drying in this region. One model, for example, finds that the Amazon rainforest could be significantly, and possibly irrevocably, damaged by a warming of 2 – 3°C."
- "The melting or collapse of ice sheets would eventually threaten land which today is home to 1 in every 20 people."
Cost of Mitigation:
In addition to the immeasurable human cost, by the end of the century a very real temperature rise of 5-6 C would result in an estimated 5-10% loss of global GDP, with poor countries suffering costs in excess of 10% GDP. In contrast, the review estimates the annual cost of stabilization at 500-550ppm CO2 e to be around 1% of GDP by 2050, with a range of -2% to +5% GDP. If mitigation to reduce emissions fails in the next 10 to 20 years, the costs of deceleration will increase and stabilization even at 550 ppm C02e will be beyond reach. As the Stern Review states, "Mitigation—taking strong action to reduce emissions—must be viewed as an investment, a cost incurred now…to avoid the risks of very severe consequences in the future."
SCOPING: THE PUBLIC'S OPPORTUNITY TO BE INVOLVED
The public will never vote on the GPT project, however, it had an opportunity to officially express concerns about the proposal during a period called scoping. The scoping period lasted for 120 days; beginning on Monday September 24, 2012 and ending on Tuesday January 22, 2013. Comments made at official sessions or submitted in writing during the scoping process will help inform the type and the geographic scope of impacts to be included in the Environmental Impact Statement (EIS). The EIS is the key document for the various agencies and individuals involved with approving or denying permits, permissions and/or leases for the project. You can view submitted comments as part of the GPT EIS scoping process.
READ MORE about Scoping
Scoping Comments:
Scoping letters should address which of the project's potential impacts that should be studied, measured and considered; these letters are not letters of support, protest, or other opinion. Scoping letters are most effective when they outline:
- specific impacts, how you and others would be affected
- thesignificance of those impacts (i.e. permanent and irreparable harm)
- the direct and indirectcosts of those impacts, and who will bear those costs
- a request for analternatives analysis (i.e. a "no action" alternative, in which the proposal would be denied; also, what the project with mitigation would look like).
Thoughtful letters by individuals presenting compelling arguments will carry great weight. If you have the time and inclination to draft your own letter, the following guides will be of assistance:
- Guide to writing scoping comments
- Scoping comment worksheet/outline
Public Scoping Meetings:
- 10/27/12 – At Squalicum High School, 3773 East McLeod Road, Bellingham, WA 98226 from 11am-3pm
- 11/3/12 – At Friday Harbor High School, 45 Blair Avenue, Friday Harbor, WA 98250 from 12am-3pm
- 11/5/12 – At McIntyre Hall, 2501 East College Way, Mount Vernon, WA 98273 from 4pm-7pm
- 11/13/12 – At North Seattle Community College, 9600 College Way North, Seattle, WA 98103 from 4pm-7pm
- 11/29/12 – At Ferndale Events Center, 5715 Barrett Road, Ferndale, WA 98248 from 3pm-7pm
- 12/4/12 – At Spokane County Fairgrounds, 404 North Havana Street, Spokane Valley, WA 99202 from 4pm-7pm
- 12/12/12 – At Clark College, Graiser Student Center, 1933 Fort Vancouver Way, Vancouver, WA 98663 from 4pm-7pm
A website has been set up for a continuous online scoping meeting at www.eisgatewaypacificwa.gov. You can also view all comments submitted through this website.
Any major development project is subject to an environmental review process required by both the National Environmental Policy Act (NEPA) and the State Environmental Policy Act (SEPA). Projects deemed too damaging to the "environment" are not permitted to proceed. More usually, projects are required to mitigate adverse impacts; these impacts are determined by the review process. Scope consists of "the range of actions, alternatives, and impacts to be considered in an environmental impact statement." Council on Environmental Quality NEPA Regulations, Sec.
1508.25, Definition of Scope In this context, "environment" is a term broadly defined, as it encompasses concerns that are chiefly human as well as issues pertaining to land, air and water quality and to ecosystems.
The Army Corps of Engineers is the lead agency conducting the NEPA environmental review for the Gateway Pacific Terminal Project. Whatcom County and the Washington State Department of Ecology are "co-leads" for SEPA. It is expected that there will be a single, joint Environmental Impact Statement, including both NEPA and SEPA, though this is yet to be confirmed.
Geographic Scope:
Whatcom County and the Washington State Department of Ecology are obligated by law SEPA, WAC 197-11-060(4)(b) to consider impacts that might affect areas outside of Whatcom County and/or Washington State as well as areas within the vicinity of the proposed coal port.
The communities close to Cherry Point will be directly impacted by the actual terminal, as communities in the vicinity of other coal terminals have had issues pertaining to coal dust.
The coal ships will navigate through the narrow passages of the Salish Sea, traversing the Cherry Point Aquatic Reserve en route. The vessel traffic and terminal site marine impacts will affect local coastal and island communities; it's difficult to draw a geographic boundary around the marine ecosystems potentially damaged by vessel traffic impacts and/or possible collision and/or spill impacts.
The rail corridor extends south from the proposed terminal site at Cherry Point, in Whatcom County, down along the Puget Sound coast to Longview, east along the Columbia River, north to Spokane, then across Idaho, and into Montana and Wyoming where the Powder River Basin coal mines are located. Residents and businesses all along this rail corridor could request that impacts to their local economies, public health and quality of life be considered as part of the EIS.
SEPA also mandates that related actions in a comprehensive system be studied: "A large proposal involving actions in vastly different locations, such as material being mined at one site, then transported to and processed at another, is another example of defining the entire proposal. Appropriate environmental review would look at the impacts of all the related activities. It is important to remember that actions are related if they are dependent on each other, so that one will not happen without the other." It is uncertain as to whether it will be argued that continued and/or new mining of coal in the Powder River Basin and the future combustion of coal at coal-burning plants currently being built in Asia are activities dependent upon and related to the transport and export of coal to and from the proposed Gateway Pacific Terminal.
Impact Categories:
SEPA has a checklist of impact categories entitled "Elements of the Environment." SEPA: Elements of the Environment.
In general, the impacts that could be studied in an environmental review include impacts to:
- Traffic (of all sorts) & Parking
- Movement of people and/or goods
- Emergency Services
- Public Service and Utilities
- Noise
- Public Health
- Land and Shoreline Use
- Aesthetics & "Scenic Resources"
- Parks & Recreation
- Historic and Cultural Preservation
- Agriculture
- Geology and Physical Features of the Earth
- Air Quality
- Water Quality and Public Water Supplies
- Energy and Natural Resources
- Plants & Animals
- Environmental Health
- Climate (greenhouse gases)
Health Impact Statement:
Health Impact Assessment: An assessment of potential health risks may also be called for. An HIA studies in detail the public health impacts of a proposed development project. Typically, it is voluntary, and can be conducted by a variety of public bodies. For example, an HIA was mandated by the Washington State Legislature and then conducted by the Public Health department of Seattle and King County prior to the permitting of the bridge on highway 520 Public Health- Seattle & King County HIA. Many Washington state physicians are calling for an HIA doctors' position statement to be conducted as part of the review process for the Gateway Pacific Terminal at Cherry Point.
For more information on NEPA:
- 14 CFR Parts 1500-1508, Council on Environmental Quality Regulations for Implementing NEPA
- 33 CFR Part 230, Procedures for Implementing NEPA (U.S. Army Corps of Engineers)
- Draft Guidance on Consideration of the Effects of Climate Change and Greenhouse Gases
- NEPA's Forty Most Asked Questions
- SEPA Homepage (Dept. of Ecology)
- SEPA Statute, RCW Ch. 43.21C
- SEPA Rules, WAC Chapter 197-11
- Whatcom County SEPA regulations: Chapter 16.08
- Draft Working Paper on Greenhouse Gas Emissions and SEPA
- Center for Disease Control Fact Sheet on Health Impact Assessments
- A Guide for Health Impact Assessment
- Health Impact Project: About the HIA
- Health Impact Project: The HIA Process
- Public Health – Seattle and King County Health Impact Assessment
PERMITTING: WHO DECIDES AND HOW
The permitting process for GPT will be complex and will involve multiple levels of federal, state and local review. Decision-makers include the Whatcom County Council for shoreline and development permits and the Public Lands Commissioner at the Department of Natural Resources for an aquatic lease (state-owned tide lands). The Department of Ecology, the Department of Fish and Wildlife and the U.S. Army Corps of Engineers must also grant approvals in order for the project to go through. These governmental bodies will consider the Environmental Impact Statement when making their decisions. The Lummi and Nooksack Nations, following their own processes, will render pivotal decisions regarding usual and accustomed fishing grounds.
READ MORE about Permitting
Primary decision makers on permits will be:
- the Whatcom County Council for shoreline and development permits;
- the Public Lands Commissioner at the Department of Natural Resources for an aquatic lease;
- the Department of Ecology for water quality and stormwater approvals;
- the Department of Fish and Wildlife for Hydraulic Project Approvals (GPT's application is still incomplete); and
- the U.S. Army Corps of Engineers for fill of 140 acres of wetlands and construction of a pier in navigable waters.
As recognized in the Cherry Point Aquatic Reserve Plan, the Lummi Nation and Nooksack Indian Tribe, with at least four other tribes, have treaty rights in the Georgia Strait, as usual and accustomed fishing grounds. Cherry Point is also known to have spiritual and cultural significance to one or more Tribes. Their approval or disapproval of the project by Tribes will be cited by the Corps of Engineers and other agencies in making their permitting decisions, based on formal government to government consultations with the Tribes. Sovereignty and Treaty Protection for the Lummi Nation has taken a "no" position on the use of Xwe'chi'eXen (Cherry Point) as a coal terminal.
Other important decision makers:
- the U.S. Congress in authorizing rail improvements needed by BNSF for rail sidings; and
- potentially federal and/or state railway regulatory bodies that require permits for new rail construction.
Permits and other considerations include:
- Shorelines: This project will be subject to study of the nearshore habitat and the shoreline habitat. Of particular interest is Whatcom County's Shoreline Management Program, at Title 23 of the Whatcom County Code.
- Forest Practices: This project will need a Forest Practices Permit under Chapter 76.09 RCW to cut trees on the site.
- Water Supply: This project will need to provide water to the site, likely in the form of water rights issued by the Department of Ecology.
- The project will require several permits under the National Permit Discharge Elimination System (NPDES).
ENVIRONMENTAL REVIEW
All major development projects are reviewed under both the National Environmental Policy Act (NEPA) and the State Environmental Policy Act (SEPA). Two major purposes of the environmental review process are better informed decisions and citizen involvement. If a proposal is likely to have significant environmental impact, as in the case of the proposed Gateway Pacific Terminal, an Environmental Impact Statement (EIS) must be prepared. The various agencies involved in approving or denying permits, leases and other permissions refer to the environmental impact statements when making their decisions. For the Gateway Pacific Terminal project, NEPA will be led by the Army Corps of Engineers. Whatcom County and the Washington State Department of Ecology will act as co-leads for SEPA.
READ MORE about Environmental Review
The U.S. Army Corps of Engineers has informed SSA Marine and BNSF that their projects (the Gateway Pacific Terminal and the Custer railroad spur) will require preparation of an EIS. It is likely that there will be only one, joint state/federal scoping process and EIS for this particular project.
An EIS is conducted by a third party; the contract for an EIS is put out for bid after the application is submitted but before scoping begins. A contractor selected and managed by the U.S. Army Corps of Engineers and Whatcom County "Tentative Project Schedule," Gateway Pacific Terminal, Multi-Agency Permit (MAP) Team, April 22, 2011 will oversee a number of studies that will constitute the EIS. The subject and breadth of those studies is determined during the scoping process.
Timeline for Environmental Impact Statements:
The environmental review process is triggered by the submission of a complete application. An application was submitted on March 19, 2012, and a Determination of Completeness was issued on April 2, 2012. It is estimated that the environmental studies will take a minimum of two years to complete.
The National Environmental Policy Act (NEPA) requires federal agencies in the executive branch of the government to undertake an assessment of the environmental effects of proposed actions before making decisions. Two major purposes of the environmental review process are better informed decisions and citizen involvement, both of which should lead to implementation of NEPA's policies.
The State Environmental Policy Act (SEPA) has a mission similar to NEPA's but allows Whatcom County and state agencies to deny or condition the project based on their adopted SEPA policies and regulations, which include the County's Shoreline Management Master Program and in particular its policies and regulations for development of the Cherry Point area. (See § 23.100.170 of the Whatcom County Code). A good starting point for helpful explanations of the SEPA process is the SEPA handbook. The handbook includes step-by-step guidance and a digest of current case law. The Department of Ecology website contains a wealth of information on SEPA, including some useful explanations of the SEPA process and a focus sheet. On July 15, 2011, the State Department of Ecology agreed that state agencies will participate with Whatcom County as co-leads in preparing a state EIS.
COMMON QUESTIONS & MISPERCEPTIONS
Would rail usage really increase, or will the coal trains come through anyway?
READ CLARIFICATION – Trains Coming Anyway?
Fact Check: Will the Trains Come Anyway, Without the proposed Gateway Pacific Terminal?
The building of the Gateway Pacific Terminal would dramatically increase rail traffic along the Puget Sound BNSF rail corridor. Although there are currently a few (2-6 total) coal trains that travel along the Puget Sound rail corridor to Canadian ports, the building and use of the proposed coal port would, by the applicant's own conservative estimates, cause a dramatic increase in the number of coal trains, adding an additional 9 fully-loaded and 9 empty (18 total) trains each day.
Proponents of the coal port at Cherry Point have often claimed that this larger number of "coal trains will come through anyway," even if the GPT facility is not approved. This assertion does not stand up to a fact check. U.S. company Arch Coal has a contract to export 2.5 million tonnes of coal per year through Ridley, Canada, but the contract expires in 2015. Canadian coal companies are currently engaged aggressively to dedicate all future export capacity to Canadian firms.
A recent analysis prepared by Sightline concludes that, even if all the planned expansion in Canadian coal export facilities went to American companies – a highly unlikely scenario – the total additional capacity of 28 million metric tons would not be enough to satisfy the planned export of U.S. coal. Peabody Coal alone has contracted with SSA for Cherry Point exports of 24 million metric tons. Canadian coal producers voiced their strong disagreement with a decision to award contracts to U.S. companies for shipment from Pt. Ridley, Canada. Thus, U.S. coal export facilities will likely drive increased rail traffic on western rail lines.
CommunityWise Bellingham has also examined the "trains are coming through anyway" fallacy and its implications for local taxpayers.
Are there any limits on coal export volumes or number of trains?
READ CLARIFICATION – Limits on Exports?
Peabody Energy has a contract with Carrix/SSA Marine to ship 24 million tons of coal annually. Sometimes people refer to tons, and sometimes to metric tons, or tonnes. In the United States and Canada, a "ton" is 2,000 lbs, whereas a "metric ton" (sometimes referred to as a "tonne") is 1,000 kg (approx 2,205 lbs). This has accounted for some variance in the capacity numbers, as has the fact that there is an initial contract with Peabody Coal for 24 million metric tons per year and a "build out" capacity of 48 million metric tons per year for the proposed coal port.
Often, a facility will be permitted for an initial capacity, even though there may be an unspoken intent to expand the facility in the future. For example, in Longview, the applicant for the coal facility proposed an initial volume of 5 million tons per year, but actually intended to expand to a much larger facility (up to 80 million tons). There is a concern that the Gateway application is for a pier and upland facility on a site that could accommodate significant future expansion; for planning purposes, it may be prudent to take the applicant's estimates of export volume and number of trains per day as minimum planning numbers. The applicant has not proposed any permit conditions that would place a cap on export volumes or number of trains per day.
Would the port be used for grain?
READ CLARIFICATION – Port Used for Grain?
There is a large surplus of export capacity at existing ports on the Columbia River, closer to grain producers in Eastern Washington. Skagit and Whatcom County are not grain-export producing markets.
An exhaustive discussion of this issue in a recent article in Crosscut concluded that the Gateway Pacific terminal would not likely lead to increased agricultural exports. After interviewing industry analysts, Crosscut noted that SSA has not contracted for any grain export leases at Cherry Point: "SSA Marine wants to present its project as a multiple-commodity port, but at this time it is only coal that seems to be a certain customer."
How Much Coal Does One Train Car Hold
Source: http://www.coaltrainfacts.org/key-facts
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