Thursday, May 22, 2014

Is There an Oil Tanker in your TIGER?

May 21, 2014

To : Interested Parties

Fr: : Dan Leahy

Re: : Southwest Washington Port-Rail Corridor Enhancement Project

Based on a Public Records Request to the Port of Centralia, I was able to pick up a hard copy of the Port's TIGER grant application for the above named project.

Amy Due, the Port of Centralia's Director of Finance and Administration, said in her letter to me of May 16, 2014 that the information I requested was “too large to send digitally.”

I distributed hard copies to Chehalis Mayor Dawes, Lewis County Commissioner Bill Shulte and Centralia City Manager. I also informed Steve Robinson, Communications Director of the Quinault Nation, about the application and the tribe has contacted Ms. Due for a copy. 

This memo is in four sections: TIGER Background, The Port's Application, Analysis. Possible Courses of Action.

TIGER Background

TIGER stands for Transportation Investment Generating Economic Recovery. It is a program administered by the US DOT, National Infrastructure Investments Program, 1200 New Jersey Avenue SE, Washington, D.C. 20590. (202) 366-0301. Since 2009, this program has distributed $4.1 billion. For fiscal year 2014, Congress dedicated $600 million. Applications for these funds total $9.5 billion as of May 15, 2014, 15 times what has been allocated for this fiscal year.

The Port's Application

The Port is the lead grant applicant requesting $9 million and Genesse and Wyoming (PSAP) said it will add $3.8 million. The total exact project cost is $$12,922.521. The Port states it will complete the project work byJuly 1, 2015.

The Port's argument is this. The late 19th century railroad linking Centralia to Grays Harbor was designed for passengers and forest products. Today, this line has become a “major export corridor for goods moving to Asia.” In fact, Mr. Heaton, Executive Director of the Port states that, “All of the export traffic destined for Asia via Pacific coast ports in Washington must first transit Centralia by rail.” Therefore, this line“must be reconfigured to serve a modern, high capacity trade corridor.”

What are those export goods headed to Asia that is turning this line into a major export corridor?

Mr. Heaton states that “For the past two years freight volume peaks for automobiles and soybeans bound for (Grays Harbor) have overwhelmed the line.” The main automobile in demand in Asia is apparently the Fiat/Chrysler made Jeep Sports Utility Vehicle (SUV). All this export traffic is, of course, projected to increase.

What will happen if the project is not funded?

Mr. Heaton spends a good deal of time arguing shippers will divert their goods to trucks which leads to pavement damage, accidents, injuries, etc. He cites “experiences of professional railroaders” who believe that “3,000 truckloads per year are currently diverted.” He uses a Benefit Cost Analysis in relation to these diversions. Unfortunately, the Benefit Cost Analysis Summary on page 27 is completed redacted and the Port did not provide me with what was referred to in the document as the “attached BCA.”

What needs to be done?

In essence, the rail corridor needs to have yards and sidings capable of utilizing “very long unit trains” and repairs have to be made to bridges and rails so that trains can increase their speeds to reduce wait time and lessen congestion at rail yards and grade crossings. In addition, the project wants to create a 1.5 mile Quiet Zone in Centralia.

Project costs are: Yards and Sidings ($8.7m). Bridges ($2.1). Surface and curves ($1.4). Quiet Zone ($500,000).

In terms of bridges, Mr. Heaton states that “All three bridges within the PSAP rail corridor are roughly a century old and well past the operational lifespan for which they were designed,” but improvements will allow increased train speeds and therefore reduced congestion.

For example, the speed at the 96 year old bridge in Centralia over the Skookumshuck River built in 1918 is now restricted to 10 MPH and leads to motor traffic congestion in the northern section of Centralia. Bridge 59 at Montesano is a 105 year old bridge built in 1909 with a speed limited to 10 MPH. Improvements will allow speeds of 25 MPH. The Wishkah River Bridge, Bridge 68 in Aberdeen, is a 105 year old bridge. Currently unit grain trains reduce speeds to 5 MPH, but with improvements will increase speeds to 10 MPH thereby reducing congestion at grade crossings.

Yards and sidings need to be able to accommodate unit trains “that are becoming the standard for customers along the PSAP.” This means an extension of the length of sidings at the Blakeslee Yard in northern Centralia and an expansion at Montesano by construction of 8,500 foot siding, approximately 1..6 miles long.

Curves are another problem area. Mr. Heaton states, “... freight volumes and weights constantly threaten to spread the rail out of gauge.” Therefore, “as speeds increase on the line, additional curved rail work should be done” in Centralia and near Oakville.


The rail system is overwhelmed by existing demand.

Let's first take Mr. Heaton at his word. The PSAP rail system is now “overwhelmed”, as he says, by soybeans, Jeep SUVs and construction equipment headed to Asia. This is why he wants $9 million dollars of our taxes to go to PSAP. This must mean there is no way for this system to be capable of accommodating the addition of oil trains. He should join the many people in Grays Harbor in calling for a halt to these proposed terminals since his rail line could not possibly move the oil trains anyhow.

No Mention of Proposed Terminals at the Port of Grays Harbor or Projected Oil Trains.

No where in the 32 page narrative or in the accompanying documents are these three proposed terminals mentioned nor their implication for 100 to 150 car unit trains carrying either Bakken shale crude oil or Alberta oil sands crude for export to Asian markets through the Port of Grays Harbor.

The absence of this discussion means that Mr. Heaton is either employing the classic bait and switch (the project is actually about getting ready to move the more profitable oil trains) or, to call upon my Irish-Catholic background, a mortal sin of omission or contextual dishonesty. A friend of mine once said, critical thought allows one to see what is not there.

Statements in the Categorical Exclusion Worksheet.

Mr Heaton filled out a “Categorical Exclusion Worksheet” asking the Federal Railroad Administration to exempt this project from a National Environmental Policy Act (NEPA) Environmental Assessment (AS) or Environmental Impact Statement (EIS).

Mr. Heaton generally argues that since all work will take place “on the current right-of-way” so there is little “impact” anywhere. There were, however, two “No” answers that caught my eye. Mr. Heaton said there would be no “cumulative impacts” and no “indirect impacts.”

Now I hate word “impact” about as much as the word “stakeholder” but how can he state “no” “cumulative” or “indirect” impact if his improvements will facilitate the movement of dangerous oil trains on the PSAP rail line to the proposed oil terminals at Grays Harbor.

Unanswered or Redacted Answers to Questions on the Worksheet.

There were at least two questions that drew my attention and there was no answer on the worksheet I received.

What resources of interest to Federally-recognized Native American Tribes are known to be present in the Project Area?

Has the Project generated any public discussion or concern, even though it may be limited to a relatively small subset of the community? Indicate any concerns expressed by agencies or the public regarding the Project.

Economic Development and Local Shippers.

The project proposal indicates that the PSAP and the Port of Centralia intend to prioritize very long, 100 car unit trains of materials produced in others states (such as Michigan) and destined for export via Grays Harbor. As these types of trains increase, Mr. Heaton states there will be “more pronounced” displacement for “smaller manifest customers shipping smaller numbers of boxcars.” My reading of port history says they were established to help small businesses against an avaricious railroad, not advance the railroad's interests. Economic development for whom?


I don't have any particular objection to improving rail service for movement of freight, but I want to know the goal of such improvements and how it improves our quality of life.

The Federal Railroad Administration (FRA) decides whether this application requires the preparation of an Environment Assessment or an Environmental Impact Statement under the NEPA.

The Honorable Anthony Foxx
Secretary, U.S. Department of Transportation
1200 New Jersey Avenue NE
Washington, DC 20590

The Administrator of the National Infrastructure Investments Program might be interested in receiving public comment on this application since no public concerns were listed on the project's worksheet and no public hearings on the project were listed in the application as being held.

US DOT, National Infrastructure Investments Program
1200 New Jersey Avenue SE,
Washington, D.C. 20590. (202) 366-0301.

Governor Inslee supported this project in a letter to Secretary Foxx dated April 24, 2014. Since that date there were three train derailments on this line within sixteen days. This level and frequency of derailments must call into question the overall competency of the G&W rail system. He did spark an unprecedented FRA investigation.

Perhaps he could send a note to Secretary Foxx stating his desire to withhold his support until he sees and evaluate the the outcome of the FRA investigation.

Jay Inslee, Governor
PO Box 40002
Olympia, Washington 98504-0002

There are no doubt many more courses of action, but that's all I got for now. Hope this memo is of some help.

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