June 12, 2013

DEQ: Comment Coal Export

475 NE Bellevue Drive, Suite 110

Bend, Oregon 97701

Oregon Department of Environmental Quality staff:

On behalf of the 1600-plus members of Wild Idaho Rising Tide (WIRT), we respectfully submit and request inclusion in the public record of these comments on three draft permits recently issued by the Oregon Department of Environmental Quality (DEQ) for Ambre Energy’s controversial Morrow Pacific Project, to regulate air, water, and storm water quality at the proposed Coyote Island coal export terminal at the Port of Morrow near Boardman.  For the record, we also ask that you integrate with this statement the comments of our allies, Columbia Riverkeeper, Friends of the Columbia Gorge, Sierra Club, Spokane Riverkeeper, and other regional organizations opposing coal export.

WIRT activists are outraged by Ambre Energy’s proposed industrial rampages beyond the geographically limited scope of rushed Oregon hearings and comment periods on these draft air and water pollution permits.  We thus demand that the Oregon DEQ further extend environmental review of this dirty energy scheme.  As DEQ has never before permitted a coal export terminal, it should support and await a more stringent U.S. Army Corps of Engineers mine-to-port programmatic environmental impact statement analysis than the Corps’ current environmental assessment.

Additional 1.5-mile-long, uncovered coal trains, each with 125 cars carrying almost nine million metric tons of strip-mined Montana/Wyoming coal per year across lands and along water bodies in Montana, Idaho, and Washington to the port, would spew toxic coal dust, diesel fumes, derailed loads, and incessant noise, disrupt local transportation, businesses, emergency responses, and economies, and degrade public health, quality of life, property values, and regional identity.  The Morrow Pacific Project open coal transfer dock and storage buildings, covered coal barges through the critical, high quality Columbia River habitat of endangered salmonid species, and exposed Port Westward docks for ocean‐going coal ships – all constructed and/or utilized to transport coal to Asian markets for combustion – would increase river traffic, compromise air and water quality, jeopardize aquatic ecosystems, fisheries, wildlife, and recreation, and significantly exacerbate global climate change.  Substantial taxpayer investments across four states would support the required infrastructure and mitigate the predictable damages of this corporate onslaught.

But the Oregon DEQ draft permits do not adequately address or circumscribe these numerous impacts of the Northwest’s first coal export terminal, sought by an inexperienced, untrustworthy, financially unstable Australian company that has never operated such facilities with unproven technologies [1].  Is DEQ aware that Ambre officials have misled Washington state and Cowlitz County personnel about the size of the proposed Millennium Bulk Logistics coal port near Longview, Washington, while obtaining permits for a much smaller export terminal than its plans for moving 60 million tons of coal per year out of the region?  How will DEQ protect the air, water, lands, wildlife, and communities of four Northwestern states from this disreputable corporation, if Oregon administrators insist on fast-tracking draft state permits before federal decisions on this project, while ignoring its full impacts and waiving their authority over them?  DEQ and the State of Oregon should consider the following contingencies and revisions, prudently require a full, rigorous analysis of coal port impacts (like the Oregon Department of State Lands did), and coordinate their presently piecemeal coal facility permits, before issuing any permits to Ambre Energy.

Coal Trains

In its narrow examination of only one facet of the Morrow Pacific coal export project – the Coyote Island coal storage site – DEQ does not deliberate the toxic pollution imposed by coal dust, coal, and diesel fumes from trains and terminals that could sully human and environmental health.  How will DEQ regulate such air and water pollution from trains, especially as it affects nearby creeks, rivers, and lakes?

Coal Barges

These draft air and water quality permits do not reference coal pollution from hundreds of coal barges in the 200-plus miles on the Columbia River between the Port of Morrow and Port Westward terminals.  How will DEQ enforce Ambre Energy use of covered, rather than uncovered, barges?  In doing so, will DEQ consider the difference in river pollution from both sources?  With the large increases of barges on the river brought by both ports, will DEQ investigate the impacts of more coal barges or spills on the Columbia Gorge Scenic Area or of additional coal ships on the Columbia River Estuary?

Air Quality

Because Ambre Energy’s coal terminal and tug boats would violate Oregon’s air quality standards, DEQ should deny its draft Coyote Island air discharge permit.  It should also mandate air and water pollution discharge permits for Port Westward coal export facilities and operations, which would transfer coal from barges to ships, and subsequently evaluate these impacts.

Water Quality

DEQ should conduct a Clean Water Act section 401 certification, to determine the entire Morrow Pacific Project impacts of coal trains, storage, docks, barges, and ships and to force compliance with Oregon water quality standards.  It should immediately notify Ambre Energy that such certification is necessary for the Coyote Island terminal dock.  Current permits also do not indicate whether pollution from facilities construction or coal storage and transport would contaminate nearby drinking water sources.

Salmon

DEQ should furthermore consider the impacts of new coal docks at the ports of Morrow and Westward, as well as the project effects of coal dust, barges, and ships on salmon and other aquatic species.  Proposed Port Westward facilities could harm a surrounding salmon nursery.

Because federal and state regulatory agencies and decision makers have obviously dismissed the comparatively rural inland Northwest again, WIRT encourages and appreciates the Oregon DEQ’s crucial inclusion of the distant voices of Washington, Idaho, and Montana citizens in the mix of comments on these draft permits.  If necessary, residents living and working along the railroad funnel between Sandpoint, Idaho, and Spokane, Washington, and/or near coal train routes through major population centers in Montana will increasingly escalate ongoing rail-side and hearing protests and legal challenges of the legitimacy of exclusionary permitting processes that do not acknowledge the concerns of communities most adversely affected by Ambre Energy’s potential regional coal export train traffic.

With great concern for the environmental integrity of the Northwest and the Earth,

Helen Yost

Wild Idaho Rising Tide

P.O. Box 9817, Moscow, Idaho 83843

wild.idaho.rising.tide@gmail.com

WildIdahoRisingTide.org & on facebook

[1] Sightline Institute, Ambre Energy: Caveat Investor (February 2013)