Comment EI-19521
Received or sent (printed as 1/7/2013)
I am a retired biologist and resident of Orcas Island, San Juan County. San Juan County is the only U.S. county entirely surrounded by water. Our islands are nestled in the Salish Sea that extends from Puget Sound in Washington State to Johnstone Strait in British Columbia. In countless ways we all are connected to communities that will be negatively impacted by the expansion of coal mining and the transport of coal by rail and by ship to Asia. My island is connected to the Tongue River Valley and to the entire globe. 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 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 greatly increased volume of shipping traffic that would result from coal terminal expansion has the potential to pollute the waters around my island when a grounding or collision occurs. Human error is not uncommon -as illustrated by the decision to tow a huge oil drilling platform, the Kulluk, in mid-winter through dangerous waters. This rig is grounded on an island south of Kodiak Island, Alaska. Combine human error with mechanical failure and/or severe weather and ecological disasters do happen. An ecological disaster in the Salish Sea would bring economic disaster to our community because we reply heavily on tourism. Because San Juan County is the geographic center of shipping within the Salish Sea, the transportation challenges of the additional coal ships only increases the concerns of county citizens. Narrowly limiting EIS studies to the Tongue River Valley railway proposal alone, while ignoring the marine transportation component, will not adequately address the concerns of the citizens of San Juan County, nor adequately represent their interests. Therefore, I request that the Tongue River Valley railway Environmental Impact Statement fully and completely include the linked and cumulative activities of transporting 50 million tons of strip-mined coal from Montana and Wyoming by rail to the proposed export terminal at Cherry Point, Whatcom County, Washington and to other Pacific Northwest ports and then transporting those millions of tons by ship through the Salish Sea to Asia. Please conduct a thorough, comprehensive, vessel traffic study that should at least include the following: 1. The increased risk of collision, allison, or grounding of all vessels while navigating the narrow, reef strewn, shipping lanes around the San Juan and Gulf Islands. What measures, if any, could reduce the risks to vessels, shorelines, and public safety from shipping accidents? 2. The increased risk and consequences to the economy, wildlife, and the environment by any oil or cargo spill in or near the San Juan or Gulf Islands. Are local and regional oil spill resources adequate to limit and then clean up a significant spill? What would be the economic consequences of a large spill on the shellfish, tourism, recreational boating and fishing industries of the San Juan Islands? 3. Given that tankers containing bitumen already use our waters, what technology and spill response capabilities exist, or would be required, to limit and clean up a spill of that product? What are the unique characteristics of bitumen that would pose a threat to the environment in the event of a spill? 4. The harmful effects on marine mammals of mechanical and surface sound propagation into the Salish Sea and the waters surrounding the San Juan and Gulf Islands. How will additional ship noise affect the foraging, rearing of young, social interactions, and possibly survivability of endangered Southern Resident Killer Whales? 5. The environmental risks of greater and greater numbers of ships using the Strait of Juan de Fuca and Unimak Pass, Alaska as the prime great circle route to Asia. What facilities and capabilities exist to assist vessels in distress while in the continental waters off Washington, British Columbia, or the Aleutian Islands? Are oil spill resources capable of responding to a spill in these waters? What would be the environmental consequences of being unable to contain a spill in these more remote waters? A comprehensive regional vessel traffic study is particularly necessary now because not only is the proposed Gateway Pacific Terminal adding ships to the already significant existing traffic but expansions are proposed for the tar-sands pipelines at Burnaby, BC and Anacortes, WA. Expansions of these facilities will contribute additional vessel transits to the increasingly crowded waters of the Salish Sea and beyond. Those of us who live in San Juan County know the inherent hazards of sailing our cold, stormy waters and foggy mist shrouded islands. Channels dedicated to large ships are narrow, sinuous, and abound in rocks, reefs and small islets. Adding more and more very large vessels to these navigational hazards will elevate all the mechanical failures, weather related accidents, and human errors to levels which are unacceptable to San Juan County and Washington State residents. Therefore, I strongly oppose the construction of the Tongue River Valley railway. Additionally, since there are currently five coal export proposals that would transport as much as 150million tons of coal through the Northwest, I urge the Army Corps of Engineers conduct a comprehensive, inclusive, area wide Environmental Impact Statement to assess the cumulative environmental impacts from all of the proposed coal export terminals. from: http://cliffmass.blogspot.com/ SATURDAY, JANUARY 5, 201 Gulf of Alaska Storms Versus Shell Oil Drilling Platform The storms win. Shell Oil made a misguided and poorly informed decision to move a huge drilling platform (the Kulluk) from Dutch Harbor Alaska to Seattle starting December 21st. As described in the Seattle Times and elsewhere the problems grew from broken tow lines and faulty engines on December 26th, to the eventual grounding the Kulluk on an island just south of Kodiak island on December 31st. The Kalluk beached south of Kodiak Island Anyone familiar with the meteorology of the North Pacific and the Gulf of Alaska knows that this region is one of the stormiest on the planet with one major storm after another during midwinter. Unbelievably, a Shell Oil spokesman said, that forecasts indicated a favorable two-week weather window. This is at odds with the facts. First, as I will show below the forecasts on the day they left clearly suggested the potential for big storms during the 3-4 week voyage to Seattle, including the first week. Second, forecast skill drops substantially after 4-6 days and thus there was no guarantee of fair weather for this difficult tow.
Submitted by: Janet Alderton · Deer Harbor, Washington
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.
Permanent address docketyard.org/d/FD-30186/comment/EI-19521 · back to the docket sheet