NY Crude oil terminal owners called to show pollution cleanup funding

Terminals would pay for multimillion-dollar risk

 
By Brian Nearing  Friday, May 30, 2014  http://www.timesunion.com/business/article/Crude-oil-terminal-owners-called-to-show-5517968.php 


Albany
A state lawmaker from Albany is proposing that oil storage terminals that handle Bakken crude oil or tar sands oil — like the two terminals at the Port of Albany — be required to put up financial guarantees to cover the multimillion-dollar costs of dealing with spills, fires or explosions.

Assemblywoman Patricia Fahy said Friday the change is needed to make sure Albany does not face the same situation as the small Canadian town of Lac Megantic, which was devastated July 6, 2013, by a Bakken crude oil train explosion that killed 47 people. The railroad company involved went bankrupt, leaving insurance that falls far short of covering billions of dollars in damage.

"We think that terminal operators should put up enough financial security to cover expenses after something happens," said Fahy, a Democrat whose district includes Albany, and the suburban towns of Bethlehem, Guilderland and New Scotland. "If anything were to happen at the oil terminals at the port, it could be a massive bill."          continue reading here
 

Thursday links and an important pdf

(A.P. photo, Dan Matthews)

Runaway Train: The Reckless Expansion of Crude-by-Rail in North America

via Price of Oil

This report (pdf) tracks the rise of crude-by-rail in North America, detailing where crude trains are being loaded and unloaded, how many trains carrying crude oil are crossing the North American continent, and who is involved in this burgeoning trade.

This report is the first in a series covering North America’s booming crude-by-rail industry and is being published in conjunction with a unique interactive online map of crude-by-rail
terminals and potential routes.

Interactive Map and Report on Oil-By-Rail, "Booming Bomb Train Industry"

via desmogblog

A new report and website released today by Oil Change Internationalprovides a comprehensive overview of the current oil-by-rail industry in North America and it isn’t a pretty picture.

The report and interactive map of the “booming bomb train industry” capture the alarming scope of this very recent development.  As the report points out, 70 times as much oil was moved by rail in 2014 as there was in 2005. That rapid expansion is continuing, placing more North American communities at risk.  

Oil By Rail - Week of Action

via Dailykos

On July 6th of last year, a train carrying explosive Bakken crude oil derailed in Lac-Megantic Quebec and the end result was a town was destroyed and 47 people died.  On July 6th of this year, activists across North America will be commemorating that tragic event and working to raise awareness about the growing dangers to people and the environment posed by the massive expansion of moving crude oil by rail.  

Wyoming governor to visit Washington to push for coal ports
via Seattle Times
Wyoming Gov. Matt Mead heads to Washington state next week to push for access to ocean ports to allow export of Wyoming coal to Asia even as many Northwest politicians and residents voice
increasing concern about the effects of burning coal on global
warming.

Mead, a Republican who says he’s skeptical global warming is caused by humans, has made trade missions to Asia and is eager to start exports from Wyoming...(snip)...Renny MacKay said the governor doesn’t intend to visit with Washington Gov. Jay Inslee, a Democrat who has expressed concerns about the prospect of exporting coal to Asia through the state.

Minnesota imposes safety fee on railroads

via Great Falls Tribune

ST. PAUL, Minn. – In the wake of fiery derailments in Canada and North Dakota, Minnesota Gov. Mark Dayton on Tuesday signed into law a measure requiring railroad and oil pipeline companies operating in the state to help pay for training and programs to prepare for emergencies.

The law empowers the state to collect a total of $2.5 million annually from railroad and oil pipeline companies until July 1, 2017. That money will help first responders get ready for derailments and spills involving oil and other hazardous substances.

That news is a relief to Scott Braith, chief of the volunteer fire department in Staples, Minnesota, a town of about 2,900 on a major freight line which sees 70 to 100 trains a day, some carrying crude oil from North Dakota's Bakken shale fields.

The Costs of Delay

What’s the Best Way to Stop Extraction? Delay, Delay, Delay.

by Bryan Farrell / Waging Nonviolence 
Earth First Journal  5/28/14

The knock on environmental protests is that they oftentimes only appear to delay the inevitable — be it forcing a coal-fired power plant to shut down for just one day or forcing the construction of a pipeline to be rerouted. But what if those delays really were more than symbolic victories? What if they amounted to something really powerful that actually imposed serious costs on industry? Well, that’s exactly what a new study says.

According to researchers from the University of Queensland, Harvard Kennedy School and Clark University, conflict has become a major contributor to the cost of projects in the mining, oil and gas industries. The researchers looked at 50 planned major extractive projects and found that local communities launched some sort of “project blockade” in half of them, leading to 15 percent of the projects being suspended or abandoned.

“There is a popular misconception that local communities are powerless in the face of large corporations and governments,” said Daniel Franks, Deputy Director of UQ’s Centre for Social Responsibility in Mining. “Our findings show that community mobilization can be very effective at raising the costs to companies.”

The research, which is based on confidential interviews with 45 high-level industry officials, found that delays caused by conflict with communities can result in the loss of $20 million per week for mining projects valued between $3 billion to $5 billion. One company’s costs reached $6 billion over two years — more than 10 percent of its annual operating profits. In general, though, protests were most successful when they took place early on, during the planning and construction phases of a project.      continued here

Train derailment still not cleaned up

Train Derailment follow up Montesano Wa May 28th 2014 from T0M FREDRIKSEN on Vimeo.

Wyden, Merkley: All oil trains should report routes, not just some

By Rob Davis | rdavis@oregonian.com 
May 9, 2014  The Oregonian

Oregon Democratic Sens. Ron Wyden and Jeff Merkley called Friday for the U.S. Department of Transportation to require more disclosure of oil train routes to first responders around the country, saying an emergency order this week didn’t go far enough.

On Wednesday, the Department of Transportation issued an order requiring railroads carrying more than 1 million gallons of highly flammable North Dakota oil in a single train – about 35 tank cars – to tell state authorities how many trains they expect to move weekly through each county. Railroads also must disclose the routes and notify the state before making significant changes to shipment volumes or frequencies.

But the order has a limited impact in Oregon because it only applies to trains carrying oil from North Dakota’s Bakken region, not other oil-producing areas.

Citing The Oregonian’s reporting on Union Pacific’s plans to increasingly move mile-long trains of crude oil from Utah on the Oregon side of the Columbia River Gorge -- shipments the order doesn’t cover -- the senators said all oil trains should have to report their routes, volumes and frequencies.
continued here 

see also:  Railroads claim national security in keeping oil train routes secret, but feds say not so

Press Release

For Immediate Release: May 27, 2014

Contacts: Kerry McHugh, 206.902.7555, kerry@wecprotects.org
Arthur (R.D.) Grunbaum, Citizens for a Clean Harbor, (360) 648-2476, rd@olearycreek.com

Concerns raised about proposed Grays Harbor oil terminals

 Threat of oil train explosions and oil spills cited as public comment period for proposals closes

HOQUIAM, WA – Citizens from across Washington continue to voice significant concerns about proposed oil terminals in Grays Harbor as the public comment period comes to an end today. Comments raised questions about the risk of oil train derailment, explosions, and the impact of an oil tanker spill on Grays Harbor County’s economy. 

“Oil terminals, oil tankers, and oil trains are a bad deal for Grays Harbor,” said Arnie Martin, President of Grays Harbor Audubon Society. “The risk to our communities from oil trains and the risk to our economy from an oil spill are just too great. As we saw with the Exxon Valdez and the BP Deepwater Horizon spills, just one accident can be devastating and long-lasting.”

Concern over the proposed oil ports drew concern from Spokane and even as far away as Montana. 

“These proposals in Grays Harbor would have very real impacts on Spokane,” said Spokane City Council President Ben Stuckart. “More trains mean increased risk of explosion, increased risk to our first responders, and increased risk to our community.”  Spokane would face a huge increase in oil train traffic, since it sits at a choke point for trains headed to port cities throughout Washington.

There were two public hearings for the proposed terminals, in Centralia and Hoquiam. At both hearings, participants were overwhelmingly opposed to the proposals. Residents of the Inland Northwest held a People’s Hearing in Spokane last week in order to voice their opposition to the proposals and their concerns about oil train impacts on their communities. Additional concerns included traffic jams and public health concerns stemming from a high volume of train traffic.

"These oil trains will bi-sect Lewis County's four largest cities with highly flammable cargo at all hours of the day, hurting our businesses and exposing residents to unnecessary risk," noted Phil Brooke, a resident of Centralia and Director of Risk Management for a large local employer.

Grays Harbor has three separate crude-by-rail proposals pending. Westway Terminal Company, Imperium Terminal Services, and U.S. Development Group each have proposed projects that would ship tens of millions of barrels of crude oil through Washington to Grays Harbor each year. The public comment period closing today is for the EIS scoping that Washington State Department of Ecology and the City of Hoquiam conducted for the Westway and Imperium proposals.

These proposals would result in crude oil coming from North Dakota to Washington via trains through Spokane, along the Columbia River, up through Centralia, and into Hoquiam. The oil would then be transferred onto tankers and pass through Grays Harbor and onto refineries or directly for export. 

Over the past year, there has been a growing opposition to these proposals. In Summer 2013, the Quinault Indian Nation, Friends of Grays Harbor and Grays Harbor Audubon won a ruling by the Shoreline Hearings Board requiring the Department of Ecology and City of Hoquiam to conduct a thorough review of the proposals. Since that ruling and as more information has become public around oil train accidents and the risks of spills, residents and community groups have been voicing concerns about the impacts of the proposals.

“The Quinault Nation and citizens throughout our region have no choice but to stand strong against oil in Grays Harbor,” said Quinault Indian Nation President Fawn Sharp. “As we have consistently stated, our people and our treaty-protected natural resources are jeopardized by these oil shipments. This danger is real. We have invested millions of dollars to protect and restore the ecological integrity of our region, and we will not allow Big Oil to destroy it.”

The past year has seen some devastating accidents:

·         In July, forty-seven people were killed when a crude oil train derailed in a small town in Canada’s Quebec Province just across the border from Maine.

·         Multiple explosions sent mushroom clouds of flames hundreds of feet into the air forcing hundreds of residents to evacuate when a 106-car crude oil train derailed in Carrolton, North Dakota in December, 2013.

·         Last month, a derailed train sent burning crude oil into the James River in Lynchburg, Virginia. “The river was on fire,”said deputy city manager Bonnie Syrcek. “We are very fortunate that the cars that derailed toward the river, instead of toward the city.”

GUEST EDITORIAL Where is our Governor?

via The Vidette -by Carol Seaman

While some, myself included, may not feel warm & fuzzy reading visceral analyses of the oil projects & those certain citizens’ fight against the doom, gloom, death and destruction of Grays Harbor County– it speaks truths–volumes. We, all need to wake up! We have hashed over the muriad of reasons the proposed 2.7 billion gallons yearly–crude oil by rail–should not come here; we have compiled statistics proving it’s a bad idea; we have shown informational power points on dangers of bringing this Bakken crude oil through communities; we have written letters to the editor; we have written to our congressmen; we have drawn pictures; we have made flyers & signs, t-shirts and buttons; we have put our hearts into this issue for all the right reasons; we have run a non-partisan candidate for Port Commissioner; now a candidate for County Commissioner. We’ve made public comment–several times. We have gone door to door warning Grays Harbor that the sky is falling–don’t miss the metaphor!After more than a year, is all this rhetoric accomplishing anything? Are we talking to the right people?

Go read more at the link. Carol is on fire!

'A Government Of Thugs': How Canada Treats Environmental Journalists:

The federal government places numerous obstacles in the way of those who try to disseminate information about the Canadian tar sands. Many believe this has amounted to a full-on war.

http://thinkprogress.org/climate/2014/05/23/3428984/canada-war-on-environmentalists/

Two thoughtful articles about our deadly economic system

 

Laying Some Groundwork for a New Economic Paradigm

by lehman scott   Tue May 20, 2014 

If I had to pick just one word to describe human civilization right now, that word would have to be "overdetermined".  I first encountered it when I was an undergraduate student working my way through French philosopher Louis Althusser's 1969 work, For Marx, where he uses it to describe the conditions that give rise to revolutions.  While that particular definition is certainly applicable to our current times, I would like to turn our attention to the more general one:

Overdetermination is a phenomenon whereby a single observed effect is determined by multiple causes at once, any one of which alone might be enough to account for ("determine") the effect. That is, there are more causes present than are necessary to cause the effect.

Let's explore this concept in two ways to see how it might help us in thinking about what we're facing in the monumental task of constructing any new economic paradigm: first, in understanding an important aspect of our brains, and second, in trying our hands at a bit of traditional political economy.  After we do that we'll poke through some of the jumbled building blocks in the rubble of the collapsed neoclassical paradigm and see where we might go from there.  …. Continued at link

A Left Solution to Climate Change

by Jack A. Smith / May 23rd, 2014

Climate change is occurring with extreme rapidity. Recent news headlines warn us: “Earth Could Warm 11 Degrees by 2100,” “Huge Antarctic Ice Sheet Is Collapsing,” and “Climate Change Risks Security and Wars.” — and this is just the beginning.

Had extreme measures been inaugurated worldwide 20 years ago to sharply curtail reliance on fossil fuels, much of what we are now experiencing — unwelcome temperature change, dangerous storms, droughts, floods, etc. — would have been minimized. But to this day Washington is among the tiny minority of countries that have refused to ratify the basic UN document on climate change, the Kyoto Protocol. 

…..Despite the reality of climate change, the major capitalist industrialized countries — most certainly the United States — are moving at a snail’s pace, if moving at all, to mitigate its decimating effects on life on Earth. At issue is whether the capitalist system is willing and able to bring about the immense changes required to prevent climate change from developing into a global catastrophe from mid-to-end century. The evidence so far is that it will not move fast enough…..continued at link

Countdown for Comments

Important Petition to sign:

"Ask Governor Inslee for a moratorium on all new oil-by-rail permits until thorough, cumulative studies (full Environmental Impact Statements) are conducted on all safety, health, and environmental impacts from transporting oil by rail through our communities. " 

Will you sign the petition too? Click here to add your name: 

http://petitions.moveon.org/sign/moratorium-on-all-new?source=s.fwd&r_by=2289844  

We need an apartheid-style boycott to save the planet

via the Guardian

Twenty-five years ago people could be excused for not knowing much, or doing much, about climate change. Today we have no excuse. No more can it be dismissed as science fiction; we are already feeling the effects.This is why, no matter where you live, it is appalling that the US is debating whether to approve a massive pipeline transporting 830,000 barrels of the world's dirtiest oil from Canada to the Gulf of Mexico. Producing and transporting this quantity of oil, via the Keystone XL pipeline, could increase Canada's carbon emissions by over 30%.

Desmond Tutu calls "climate change a huge enemy"

via The Sydney Morning Herald

"We have only one home. This is the only home we have. And whether you are rich or poor, this is your only home ... you are members of one family, the human race."

From Don, here's what you need to do, and make all your friends do:

Hello Friends,

Only four days left to submit scoping comments regarding the oil terminals in Grays Harbor.

Has your fire department submitted one?

If the oil terminals in Grays Harbor are approved, the trains headed there will endanger neighborhoods along the tracks headed north from Vancouver, through Kelso, Centralia, Elma and Hoquiam.

Those terminals will receive three oil trains per day. 

1.  Please save the following link,

2.  Then copy and paste this link into relevant on-line comment sections of every newspaper between Spokane and Hoquiam.

This link is for a new Sierra Club tool which will make it easy for concerned citizens to ask the Department of Ecology to study the cumulative impacts of all the oil trains in their community.

https://secure.sierraclub.org/site/Advocacy?pagename=homepage&page=UserAction&id=13671&s_src=710ZSCSH01#.U31TITIyLig.facebook

3.  Then post the link on Facebook.

4.  Then submit multiple comments of your own.

Names of newspapers:

• Spokesman Review
• Tri-Cities Herald
• The White Salmon Enterprise
• The Skamania Pioneer
• www.TheGorge.com
• The Camas Post Record
• The Columbian
• The Daily News (Longview Kelso)
• The Centralia Chronicle
• The Olympian
• The Daily World (Aberdeen Grays Harbor

Global Warming’s Six Americas; An Audience Segmentation Analysis

Thank you for being "alarmed"

The Alarmed (18 percent of the U.S. adult population) are the segment most engaged in the issue of global warming. They are very convinced it is happening, human-caused, and a serious and urgent threat. The Alarmed are already making changes in their own lives and support an aggressive national response (see graphs below).

Justify Bakken Testing

via RailwayAge  

The Department of Transportation hazardous materials regulator has quickly challenged the refinery lobby's contention that Bakken crude falls comfortably within existing "Class 3 Flammable Liquid" and should continue to be transported in the DOT-111 general purpose tank car.
In a May 21, 2014 letter to Charles Drevna, president of American Fuel & Petrochemical Manufacturers, the top executive of DOT's Pipeline and Hazardous Materials Safety Administration requested details of the testing methodologies and sampling techniques that led the refiners' special interest group to call for a halt to development of a next-generation tank car.
The refiners want a thorough analysis of railroad derailments before any new design to replace both the DOT-111 and the railcar industry's self-imposed CPC-1232 specification. Keeping the cars on the track should be the priority, says the refiners lobby, whose members operate much of the DOT-111 fleet.

Refiners’ lobby says DOT-111 is “fine” for shipping Bakken crude

via Railway Age 

While the AFPM supports regulatory adoption of the 2011 standard proposed by a cross-industry committee, Drevna said he doubts that Canada's phase-out of DOT-111s can be accomplished within the three-year timeline. Any additional new tank car specification beyond the industry-sponsored CPC-1232 standard should be delayed until comprehensive derailment data has been collected and analyzed.
No practical tank car would have survived the 64-mph derailment of Montreal, Maine & Atlantic's runaway at Lac-Mégantic, said Frits Wybenga of Dangerous Goods Transport Consulting, who on behalf of AFPM analyzed a survey of Bakken oil samples by organization members. “You can’t design-out a tank car rupturing in those circumstances. You can make them heavier and heavier and make a tank car that would withstand those forces, but you wouldn’t be able to carry much crude oil in it.”

Train #4 Derails North of Centralia

Train Derails North of Centralia

via Chron Online
Posted: Thursday, May 22, 2014 11:00 am | Updated: 2:16 pm, Thu May 22, 2014.
By The Chronicle | 0 comments
A train derailed from the Puget Sound and Pacific Railroad north of Centralia early Thursday morning.
Large sections of rail in the area of Foron Road were severely damaged, and several cars were sitting off track, but none were flipped over. It does not appear any materials or products were spilled. However, large sections of the rail were torn from the ties and lying on their sides, while in other sections the rails were missing completely.

*(ed note) technically, this derailment was brought to you by the Port of Centralia's rails and cannot be blamed on PSAP in any way, regarding the recent inspection of all 56 miles of track by a geometric car, which found they were completely safe.

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. TIGERgrants@dot.gov. 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 19^th 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.

Analysis

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?

POSSIBLE COURSES OF ACTION

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.

TIGERgrants@dot.gov.

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

www.governor.wa.gov

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