The scope of the sweeping coal export proposal’s environmental impact statement (EIS) announced [yesterday] by the Washington State Department of Ecology meets the rigorous and comprehensive test legislators presented to our Governor and Ecology Director earlier this year.
We said in our outreach, plainly and clearly, that the state needs to thoroughly evaluate the net impact of the proposed Gateway Pacific Coal Port on our existing centers of commerce in order to accurately understand the legitimate economic, transportation, health and environmental implications on our state’s economic future. (Legislators’ letter and comprehensive background material is provided here).
In 2012, Governor Gregoire, Attorney General Rob McKenna and Congressman Jay Inslee each called for a comprehensive, cumulative impacts analysis of the coal export plans. This initial EIS scope represents the tactical implementation of that policy position, and represents the level of analysis legislators have also embraced. As described by Ecology today, the environmental review process will provide the thorough level of interdisciplinary, coordinated and cumulative review legislators requested and the 6.8 million people of Washington deserve.
My constituents in Seattle, and communities statewide impacted by the proposal, are demanding this serious and in depth level of analysis. This is not about one town or city, one philosophy or policy framework, it is about a systems approach to an international issue. Proponents and opponents should not fear a robust public process and examination.
The troubling story behind the headlines, however, is the lack of policy thought leadership by the federal government. The U.S. Army Corps of Engineers, as the lead federal agency, is focusing under NEPA on a narrow examination of impacts solely under their direct authority. At a time when the federal government is virtually paralyzed by the institutional grip of inaction–despite President Obama’s call for proposals to be examined through a measurable environmental framework–it is jolting to recognize that no broad-based federal assessment, review or examination is occurring on this massive interstate commerce issue. The federal government’s deafening silence is a clarion call of action to Olympia, Salem, Boise, Helena, Cheyenne and other state capitals to dust off the 10th Amendment to the U.S. Constitution itself to defend our individual and even regional interests against a lethargic federal bureaucracy.
I am particularly pleased that the scope of the EIS will examine the significant proposed increase in rail and vessel traffic and what this added congestion will do to our existing routes of commerce—including at the right stage King County as the heart of our state’s economic engine—and what the cumulative impact of the Gateway Pacific Coal Port proposal and other coal export proposal might have on our state rail system. Under the state Department of Transportation projections, for example, rail traffic is expected to double in Washington under normal economic growth by 2035–not including this statewide proposal. With this proposal’s additive 18 or more additional trains per day through downtown Seattle, on top of the 60-70 baseline each day currently, the long term strategic interests and implications must be better understood to ensure a 21st Century infrastructure. Vessel traffic throughout Puget Sound must be understood at the economic, environmental, commercial and safety levels.
Moreover, the EIS scope will examine the cumulative impact of the proposed increase in rail traffic from both the Gateway Pacific Project and the Millennium Project in Longview on our vital freight corridor. The fact that these two projects would potentially add over 30 coal trains a day in centers of commerce such as Spokane highlights the need for examination of mitigation options and cost.
The proposed EIS will enable an examination of the impact that coal trains would have on the ability of Washington businesses to move goods to and from port, and the complications to vehicle movement that would arise in areas where roads and railways intersect. Additional rail traffic would exacerbate existing rail congestion issues, and the incremental impact of this proposal on rail is substantial by any definition. The likelihood of increased short-haul freight costs (for example apple transport between Wenatchee and Seattle) serve as a further externality of the plan. These impacts will receive a thorough analysis under the EIS and will enable our ports, cities, and counties to assess potential impacts to their business and community centers.
Specifically: Under both NEPA and SEPA, the three co-leads will conduct extensive analysis of the projects’ on-site and nearby impacts, including wetlands, shorelines, water and air quality, cultural and archeological resources, fish and wildlife, noise and vibration, among other possible effects. A detailed evaluation of the projected 974 annual vessel trips associated with the terminal also will be assessed.
Under SEPA, Whatcom County and Ecology will require:
§ A detailed assessment of rail transportation impacts in Whatcom County near the project site, specifically including Bellingham and Ferndale.
§ An assessment of how the project would affect human health, including impacts from related rail and vessel transportation in Whatcom County.
§ An evaluation of greenhouse gas emissions from terminal operations, and rail and vessel traffic.
In addition, the Department of Ecology will require:
§ A detailed assessment of rail transportation on other representative communities in Washington and a general analysis of out-of-state rail impacts.
§ An assessment of how the project would affect human health in Washington.
§ A general assessment of cargo-ship impacts beyond Washington waters.
§ An evaluation and disclosure of greenhouse gas emissions of end-use coal combustion.
We are a pro-trade, pro-growth, pro-economic infrastructure state, but those international values do not require us to blindly support a stale 19th Century proposal to ship an aging commodity to weakening Asian markets. Those values call upon us to be more strategic and forward thinking.
More than 125,000 people commented over 121 days on the coal export proposal during the EIS scoping development process. Legislators, business and labor interests, environmental activists, small town and big city mayors and many others spoke out to include their voices in this process. By any definition in this long, laborious public process the Department of Ecology responsibly and carefully listened to all of those diverse voices in taking this step forward.
This is only one step in a long and vital public process. Much work remains to be done. But this is a good day for transparency and a fair, open and robust public examination of our state’s future.
At the same time, while Ecology’s role in the EIS shows a concern for the wide ranging operational issues, they are not examining the core question of wisdom of the policy and business decision itself. That is our job as public officials and as citizens. A new Goldman Sachs research report, independent of the company’s internal investment arm, presents an extraordinary data-driven outline of the weakening demand for thermal coal in China and Asia that is the very core of the coal export proposals justification in the first place. These structural economic issues must be examined as part of a broader public policy debate. It is essential–now more than ever–that the people of Washington engage and the Governor and Legislature exercise leadership.
We are so much more than what we’ve become.
Your partner in service,