Comment EI-19520
Received or sent (printed as 1/7/2013)
I am deeply concerned about the potential impact on public health and the environment from the various proposals to transport coal from Montana and Wyoming to terminals on the Pacific Coast for export to Asia. The proposal to build a coal-hauling railroad line through the Tongue River Valley seems especially misguided for two main reasons: 1) it would have negative impacts on the residents, the quality of life, and the environment in the Tongue River Valley; and 2) it would contribute to similar negative impacts for the residents, the quality of life, and the environment in the Pacific Northwest in general. Regarding the Tongue River Valley rail proposal, the environmental impact statement for the proposed Tongue River Railroad should analyze the following: Public convenience and necessity: This proposed railroad is not for the “public convenience and necessity” which is what is required in order for a body to get the power of eminent domain and condemnation authority. This railroad would serve only one coal company giant, Arch Coal, which intends to sell the coal to China and other Asian countries. Impacts on property values: The project would devalue property and infringes on property rights. This railroad will cause fires, spread weeds, devalue property (especially riverfront property), will make ranching and farming more difficult and expensive, will split ranch land in half and separate fields from the river and will shift the liability of train crossings to the landowner. Wildlife: The Tongue River Valley is rich in wildlife habitat and home to outstanding elk and mule deer populations as well as upland birds. Industrializing this valley with a railroad and the coal strip mine it serves will seriously degrade this excellent sportsman resource. Flooding: The railroad bed will act as an earthen dam and potentially worsen the flooding problems now experienced in Miles City in the winter with ice jams. Noise: The loud trains will ruin the quiet enjoyment of nearby recreation areas near Miles City. Infrastructure and traffic: Taxes will go up for residents communities along the rail lines as the coal heads to coastal ports for shipment. This railroad will increase coal train traffic substantially causing traffic delays, noise, and diesel pollution. The only way to live with this increased traffic will require expensive over passes and safety crossing which are paid for primarily by local taxpayers. Because it is part of a larger project to export coal from the US to Asia through ports on the Pacific coast, the proposed Tongue River Valley railroad would have much more extensive impacts. I believe that a responsible EIS will take these impacts into account. For example, the proposed Cherry Point Terminal in Northwest Washington for the coal transported by rail will impact marine life along the Pacific Coast and the Puget Sound. Copper is an environmental contaminant that is highly toxic for aquatic plants and animals. See: http://magazine.mining.com/Issues/0904/ImpactsCopperAquaticEcosystemsHumanHealth.pdf. For railways that are close to the marine shoreline or to wetlands, cumulative copper releases could present a significant source of pollution. Wetlands that lack an outlet and poorly flushed marine areas would be at greater risk. Many miles of the railway that would carry the increased traffic generated by the Gateway Pacific Terminal Expansion are located near the marine shoreline or near wetlands. Copper pollution from the expanded terminal could impact the unique and ecologically significant Cherry Point herring population. The study cited below found that about 9.4 kilograms (20 lbs) of copper was released into the environment per kilometer of railway per year. Twenty pounds of copper per kilometer per year equals 200 pounds of copper for every six miles of railway per year. This is for rail stretches where the trains are not accelerating or braking. Larger amounts of copper would be released at railway terminals and in maneuvering areas, such as at the proposed Gateway Pacific Terminal. The Gateway Pacific Terminal is upland from the Cherry Point Herring spawning grounds. The negative impact of copper from railways on this genetically unique strain of herring could be significant. The contamination would be cumulative over the life of the terminal. If the Gateway Pacific Terminal expansion is approved, copper contamination could pose a significant threat to the aquatic ecosystems that are near the railways that experience increased traffic. Approximately 80% of the copper pollution generated by railways is released to the atmosphere and soil. This measurement of copper release from railways into the environment is derived from the following reference: Long-term Management of Track Ballast- A Case Study In Prevention and Recycling of Large Waste Flows" Ulrich Kral, Vienna University of Technology and Paul H. Brunner, Vienna University of Techology presented at the 2010 ISWA World Congress This study shows that significant amounts of copper are released from level sections of railways where trains are neither accelerating nor braking. 9.4 kilograms of copper per kilometer of railway were estimated to be lost to the environment per year. 9.4 kilograms per kilometer per year equals 200 pounds per six miles per year. http://www.railway-research.org/IMG/pdf/b4_kral_ulrich.pdf http://www.iswa.org/uploads/tx_iswaknowledgebase/Kral.pdf The results of this study show, that gravel, contact wire, and brake pads are sources of equal importance for copper release from the railroad stretch investigated."
Submitted by: Gerri Gunn
The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.
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