The state Department of Ecology should take a firm stand on behalf of sound science and deny the permit for this unpopular, poorly conceived coal terminal.
THE state Department of Ecology will soon make an important permitting decision that could well pit Washington state against the federal government. The proposed Millennium Bulk Terminal-Longview project must obtain a Clean Water Act Section 401 permit from the state before construction could begin, certifying that it will not significantly impact state and tribal waters. A denial of this permit would fly directly in the face of Trump administration efforts to resuscitate the dying coal-mining industry in attempting to assert U.S. “energy dominance.”
This is the one Pacific Northwest coal-terminal project still standing from the original six proposed early in the decade. If built, it could export up to 44 million metric tons annually of Powder River Basin coal mined in Montana and Wyoming. Proponents tout the thousand or so temporary construction jobs and 135 permanent jobs the project would generate, plus annual millions in tax revenues. If the terminal is not built, mining companies will have to continue shipping coal by rail through the state to Westshore Terminals near Vancouver, B.C.
This low-grade thermal coal, burned principally by utilities, is particularly dusty, resulting in “fugitive” coal dust polluting local environments if not properly contained during transport and shipment. Project proponents claim this will not be a serious problem due to mitigation measures to be enacted. But a critical examination of calculations involved in estimating these coal-dust emissions at the planned terminal, which I presented in three comments on the draft environmental-impact statements and the Section 401 permit application, show that these estimates are extremely low, by factors of up to 7, mainly because of very optimistic assumptions used in the analyses.
For example, the lowest imaginable dust content was used for the coal, 2.2 percent, while no measurements of its actual dustiness were obtained from coal trains chugging past Longview en route to Canada. And these calculations assumed 95 to 97 percent efficiencies for suppressing coal dust in transfers to and from storage piles when 80 to 90 percent is far more reasonable based on real-world experience. To practiced eyes, this smacks of deliberate lowballing.
The problem is worst near terminal piers, where coal is to be transferred from open conveyor belts to waiting bulk carriers, much like at Westshore. Almost all the losses to occur here, nearly 14 metric tons annually by my estimates, would fall directly into the Columbia River below, impacting benthic habitats nearby and downstream of the terminal — as well as any fish, including salmon, traversing these waters and feeding there.
Other coal-dust losses impacting river waters would occur upstream, where eight uncovered coal trains would traverse the windy Columbia Gorge daily, often traveling immediately along the river’s edge. And losses into Columbia tributaries crossed by these trains would eventually find their way into the river, too, given how readily the dust floats. Such aquatic impacts, which could easily exceed the contamination near the terminal, were not properly treated in the environmental-impact statements.
In addition, 37.6 million metric tons of carbon dioxide would be emitted by these trains and terminal operations over a 20-year terminal lifetime, according to the state’s environmental-impact statement. At about $40 per ton, the currently accepted social cost of carbon, that comes to more than $1.5 billion in damages globally. Including the approximately 100 million tons of carbon dioxide from burning this coal in Asia pushes the total annual damages over $4 billion. Some of that would further impact our state coastal waters, where ocean acidification has already begun harming young shellfish.
Although the Trump administration forces try to deny it, the science of climate change and its impacts are clear — and accepted by the vast majority of knowledgeable scientists. And the impact of coal dust on marine life is fairly well established. The Department of Ecology should therefore take a firm stand on behalf of sound science and strike a resounding blow against unreason by denying the permit for this unpopular, poorly conceived project.