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 Law Office of Robert Ukeiley 

507 Center Street ◦ Berea, Kentucky 40403 ◦ tel.859-986-5402 ◦ fax.866-618-1017 

Robert Ukeiley 

rukeiley@igc.org 

VIA EMAIL 

February 22, 2013 

Jeff Hunt, EPA Region 10, 

Office of Air, Waste and Toxics (AWT–107), 

1200 Sixth Avenue, Suite 900, 

Seattle, WA 98101 

Email: R10-Public_Comments@epa.gov

 RE: Revision to the Washington State Implementation Plan; Tacoma-Pierce 

 County Nonattainment Area 

 EPA–R10–OAR–2012–0712; 

Dear Mr. Hunt: 

 On behalf of the Sierra Club and its many thousands of members and supporters who are 

at risk of adverse impacts of exporting coal mined in the Powder River Basin (PRB) via ports on 

the West Coast, we are writing to comment on the 2008 Baseline Emissions Inventory and 

Documentation for the Tacoma-Pierce County PM2.5 Nonattainment Area (Tacoma Emission 

Inventory). The United States Environmental Protection Agency (EPA) has assigned this action 

Docket EPA-R10-OAR-2012-0712. 

 As explained in detail below, the West Coast is facing potentially five new coal export 

facilities that would export coal mined in the PRB to Asia. Coal would be transported via rail 

and/or barge to the ports and then shipped abroad. There are also existing coal trains traveling 

through Washington to Canadian ports. Finally, trains carrying tar sands oil to refineries may 

also rapidly increase. Thus, it is imperative that the Tacoma Emission Inventory clearly and 

accurately document emissions from trains as this railroad track stands to have substantially 

increased traffic due to export facilities . An accurate emission inventory is necessary not only 

for the Tacoma nonattainment SIP but also for proper implementation of general conformity 

determinations by federal agencies, such as the Bureau of Land Management, which authorize 

the coal mining which produces the coal which may be exported. 

 
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I. PRB MINES 

 The PRB is located in northeastern Wyoming and southeastern Montana. Several coal 

mining companies within the PRB have expressed interest in exporting coal to Asia. These 

companies, and the mines with which they are affiliated, include: Peabody Energy, Arch Coal, 

Cloud Peak Energy, Westmoreland Coal Company, Ambre Energy, and First Energy. Each 

company and its mine holdings are discussed in more detail: 

1. Peabody Energy 

 Peabody Energy has nearly 9 billion tons of reserves and manages or owns interests 

in 28 mining operations in the United States. See 

http://www.peabodyenergy.com/Operations/CoalOperations.asp. Peabody Energy has shown 

great interest in the coal markets in Asia, including China and India, for electricity and steelmaking purposes. According to their most recent “Analyst and Investor Forum,” they are 

planning to sell PRB coal to Asia, and are looking at joint ventures 

there as well: “The real goal here is to see if we can’t get large volumes of Powder River 

Basin coal to Asia,” said Peabody Coal CEO Gregory Boyce, “obviously it's a longerterm 

project. See http://www.peabodyenergy.com/pdfs/Session%202%20-%20Navarre.pdf 

“Our goal is to get large volumes of Powder River Basin [western U.S. 

Powder River Basin] coal to the Pacific Rim. We know we can sell it in China and 

Korea.” See http://www.businessspectator.com.au/bs.nsf/Article/Coal-miner-Peabody-eyesAustralia-Mongolia-expansi-6QPGV?OpenDocument. They cite the PRB’s optimal location, 

premium metallurgic and thermal coal reserves, lower cost for a seaborne supply, high potential 

for growth and expanding export capabilities with rail/port access as reasons for expanding 

mining for export to Asian markets. Peabody also expects that the world demand for coal 

(metallurgic and thermal) will rise in the next five years, which will necessitate higher annual 

exports. Peabody will consider constructing an export terminal that can hold a capacity in excess 

of its initial estimation of 20-30 MT, and has announced plans for that terminal to be 

Cherry Point in Bellingham, WA. 

2. Arch Coal 

 Arch Coal is one of the country's largest coal producers, behind industry leader 

Peabody Energy. Arch Coal produces roughly 120 million tons of coal a year from about 

20 mines in the western US and Central Appalachia, with an estimated 2.8 billion tons in 

reserves. Arch also owns and operates Arch Coal Terminal near the Ohio River, which is 

primarily used to store and ship its Appalachian coal. 

 In its 2011 Global Metals/Mining Conference presentation, Arch Coal expressed 

great interest in coal exports to Asia and predicted that by 2015 the company could be 

exporting as much as 90 million tons of coal/year. Currently, Arch Coal has access to 

seaborne coal markets through its holdings on the East Coast (DTA at Newport News, 

VA), West Coast (Ridley Terminals) and Gulf region (river facilities in KY and IL). 

Arch also acquired a 38 percent stake in the proposed Longview, WA, export terminal 
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site for $25 million plus other benefits with the expectation that this site would be utilized 

to export coal to Asia. 

3. Ambre Energy 

 Ambre Energy is an Australian-based mining and technology company that 

purchases oil shale and coal resources in Australia and the U.S. The company is involved 

in steel manufacturing, electricity generation and coal-to-liquid conversion. They operate 

surface mines in North Dakota, Wyoming and Montana. Their U.S. operations are based 

in Salt Lake City, UT, although a majority of their coal operations are based in Australia. 

An increase in the price of extracting coal in Australia has led Ambre energy to 

seek cheaper resources in coal producing areas of the United States. They have used 

various parameters to find viable areas to mine, including transportation options, 

financial modeling, and negotiation of contract terms with appropriate parties. According 

to their yearly report (2009), if conditions are favorable, they will move to acquire at least 

one operating mine in development sites it has marked. Despite the recession and 

uncertainty in financial markets over the price of coal, Ambre Energy is confident that 

they will gain the necessary financial backing for a mine acquisition. 

4. Cloud Peak Energy 

 Cloud Peak Energy operates three coal mines located in the Powder River Basin. 

The company was formerly a subsidiary of Rio Tinto, and is capable of producing about 

100 million tons of coal annually. It has 1 billion tons of coal in reserves. Originally 

formed in 1993 as Kennecott Coal, it changed its name to Rio Tinto Energy America 

(RTEA) in 2006, and went public as Cloud Peak Energy in 2008. 

Cloud Peak owns dedicated storage space at the Vancouver, BC, Westshore 

Terminal, where it has been successfully exporting coal to Asia. See 

http://www.coalage.com/index.php/features/504-cloud-peak-energys-spring-creek-rampsup.html. The company exported 3 million tons of thermal coal to Asia through the Westshore 

terminal last year, which was nearly double the amount it exported in 2009. See 

http://www.coalage.com/index.php/features/992-west-coast-exports-materialize.html. See also 

http://billingsgazette.com/business/article_23a03acc-53be-5ed3-a2fb-ff75909c3f34.html. 

Colin Marshall, chief executive officer of Cloud Peak Energy has stated in late 

2010, “expansion is absolutely more than a pipe dream” Marshall has also stated that the 

only limiting factor is terminal capacity. 

5. First Energy 

 FirstEnergy is a diversified energy company headquartered in Akron, Ohio. In late 2009, 

as part of joint venture with The Boich Group and Global Coal Sales, First Energy purchased the 

Bull Mountain mine and renamed it Signal Peak Mine. Since then, more the $450 million 

dollars has been invested in the mine, and contracting a 35 mile railroad spur that leads to 
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the BNSF's main rail line in Broadview, Montana. Due to these enhancements, mine 

representatives have projected that production at Signal Peak could reach 14 million tons 

a year as early as 2011. See http://www.montanacoalinvestment.com/john-baugues-jr.html. 

First Energy has significant interests in exporting the coal it produces and although either 

company refuses to confirm the report, it is rumored that Signal Peak has 

already successfully shipped two Panamax cargoes, 60,000 to 70,000 DWT and a capsize 

load, 125,000 tonnes, through Vancouver, British Columbia. Don Drabant president of 

Global Coal Sales Group has also stated: "We're getting some traction in Asian thermal 

markets, and we're in discussions with several people about term business in the Pacific 

Rim market." See 

http://www.steelguru.com/raw_material_news/Global_Coal_to_send_several_trial_cargoes_of_c

oal_to_Asia/112615.html 

First Energy has also indicated it has intentions to begin mining in the exact 

location of the recently announced Bureau of Land Management coal lease sale starting 

in 2013. The BLM leases are on 61 million tons of federally-owned coal and will be 

auctioned through a competitive bidding process late in the summer of 2011. There is no 

official word on how much of the 72 million tons of private and state coal reserves First 

Energy intends to buy. See http://www.victoriaadvocate.com/news/2011/apr/20/bc-mt-coalsale1st-ld-writethru/?business&business-wire 

II. EXPORT TERMINALS 

 Within the Northwest, there many ports that would have the potential to export coal. 

A. Ports 

 Washington State has eleven (11) deep draft ports, including seven (7) in Puget 

Sound, one (1) on the Washington coast, and three (3) on the lower Columbia River.26 

Powder River Basin coal shipped on BNSF rail lines can access each port. There are five active 

coal export proposals including: Cherry Point/Bellingham and Longview, WA; Coos Bay, 

Morrow and St. Helens, OR. Additionally, there are three terminals in Canada, and some U.S. 

coal travels by rail through Washington to reach these ports. 

B. Northwest Coal Export Proposals that would impact Tacoma 

1. Washington: Cherry Point/Bellingham—Gateway Pacific Terminal—SSA Marine 

and Peabody--24-50 MTPA 

 In late February 2011, Peabody Energy, the world’s largest coal company, 

announced plans to export 24 million tons of coal from a large new shipping terminal to 

be built at Cherry Point, north of Bellingham. However, Fred Palmer, a senior vice 

president for Peabody was quoted saying the Cherry Point terminal “could reach up to 50 

million tons per year.” It signed an agreement with SSA Marine, the largest terminal 
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operator in the world.1 Peabody, the largest coal company in the United States, had been 

hinting since last fall that they were looking to announce a new West Coast port space by 

year’s end that could ship 20 to 25 million tons of coal annually, which is the Cherry 

Point terminal. 2

However, the terminal may also serve other coal companies apart from 

Peabody.3

 The cost estimates for such a terminal were $400-500 million, with a construction 

time of 18 months. The facility’s capacity would be around 25 MTPA, which is more 

than twice the current PRB export to Asian markets (around 10 MTPA). 

2. Canadian Ports 

 Arch Coal announced that it had reached an agreement with 

Canadian Crown Corporation Ridley Terminals Inc. in Prince Rupert, British Columbia 

to export 2.5 million tons of PRB coal annually. 

The U.S. coal being shipped via the Canadian ports is likely shipped via Washington through the 

Tacoma area. The 2.5 MTPA from the Arch deal likely adds 1-2 trains/day to Washington rail 

routes.4

III. RAILROAD CONNECTIONS 

A. Potential rail routes 

 Burlington Northern Santa Fe (BNSF) railroad has major rail lines that stretch 

from the PRB to Washington, near Woodland and the port of Longview and Cherry 

Point. The port at Longview has eight berths, seven of which are rail accessible in 

varying capacities: directly accessible, direct transfer, transfer into storage and hopper to 

rail. The port at Cherry Point will feature berths for three ships and will be linked to the 

shore by a 1,250 foot trestle that will move cargo to or from the ships in enclosed 

conveyor systems.5

 

One rail route for Canadian or Cherry Point coal would be from Billings, MT, west to Sandpoint, 

ID, and then northwest to Cherry Point/Bellingham (All BNSF) – 1,003 rail miles. The same 

route extends to Canada. See http://www.wstc.wa.gov/Rail/RailFinalReport.pdf

In order to move 20-30MTPA along one of these rail routes, BNSF must move 55,000-82,000 

                                                            

1 See http://phx.corporate-ir.net/phoenix.zhtml?c=129849&p=irolnewsArticle&ID=1533973/ 

2 See 

http://www.oregonlive.com/environment/index.ssf/2010/09/global_mining_companies_are_fo.ht

ml. 3 http://www.coalage.com/index.php/features/992-west-coast-exports-materialize.html 4 See 

http://news.archcoal.com/phoenix.zhtml?c=107109&p=irolnewsArticle&ID=1517028&highlight

; http://www.rupertport.com/ridleyterminals.htm. 

5 See http://www.gatewaypacificterminal.com/project/what.shtml . 
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tons of coal/day. 

 Additionally Cherry Point is projected to be 48-54 MTPA. At volumes of 50 MTPA, that 

amounts to more than 22 loaded coal trains, each more than a mile long. And to support both 

Longview and Cherry Point, it is likely that additional rail capacity would be needed, or that 

existing freight traffic would be impacted. According to rail line operators, issues of congestion 

at chokepoints, slower train velocities, delayed trains, and shortages in locomotives, equipment 

and crew makes the addition of 5-7 trains/day unrealistic with the current system. Additional 

pressure on the Washington rail system will increase in the next decades. Between 2005 and 

2025, the output of the Washington State economy (measured as gross state product) is expected 

to grow at an average of 3.5 percent per year. The total freight tonnage moved over the 

Washington State rail system is expected to increase by about 60 percent over the period. To 

accommodate this growth, many more rail lines within Washington State will be operating at or 

above their practical capacity.6

 

 Washington’s current Transportation Plan (2007-2036) heavily funds the northsouth 

rail lines ($200 million).7

 Even though there is $1.15 million earmarked for a study on capacity 

constraints on mainlines, major projects and studies for the east-west line are going unfunded. In 

order to remedy this, $114 million has been budgeted for funding of regional development 

projects and mitigation of impacts on the east-west rail line, and the problem has been flagged as 

“unfunded, high priority” for the next transportation study, currently out for public comment. 

The plan does not make any specific references to which rail lines or terminals servicing these 

lines would be part of the development project. 

B. Impacted Rail Communities 

On the Powder River Basin side, more 50 trains per day would be necessary to transport 140 

million tons of a coal a year to the West Coast. Communities along the rail 

line, from the Powder River Basin in Montana and Wyoming, to Idaho to Washington 

and beyond will experience increased rail traffic through their communities. In 

communities split by rail lines, this could significantly increase the amount of coal dust 

emitted into the air and water, impact local air quality from increased train and ship diesel 

emissions, delay traffic, cause delays for emergency vehicles, increase noise pollution, 

and enhance the likelihood of pedestrian accidents and auto-train collisions. 

There are several different communities across the western United States that 

currently and would increasingly be impacted by coal trains on a daily basis. Below is list 

of some of the different potential scenarios given the emphasis on exporting coal from the 

state of Washington: 

• Taking the northern line out of Spokane the communities would be 

Wenatchee, Monroe (west side of Cascades), and then after meeting up with 

the north-south running line, Everett, north of Seattle. Much of this line is 

                                                            

6 See http://www.wstc.wa.gov/Rail/RailFinalReport.pdf (p.10) 

7 See http://www.wsdot.wa.gov/NR/rdonlyres/083D185B-7B1F-49F5-B865-

C0A21D0DCE32/0/FinalWTP111406.pdf. 
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designated as congested • Taking the middle line out of Spokane the communities would be 

Kennewick, Yakima including Yakima Indian Reservation, Ellensburg (on 

outskirts of town), and then after meeting up with the north-south running 

line, Auburn, just south of Seattle. 

• Taking the southern line out of Spokane the communities would be 

Kennewick, Vancouver turning north running along the I-5 corridor and 

hitting the town of Centralia. Then it hits Lakewood entering the SeattleTacoma metropolis where it meets with the middle line at Auburn. Running 

north from Auburn that line goes through Kent, Renton, Seattle, Richmond, 

Edmonds, and then meets with the north line at Everett. 

At Everett all three lines merge and the one line runs north through 

Marysville, Mt. Vernon, Burlington , Bellingham and into Canada. 

IV. TACOMA EMISSION INVENTORY 

 As EPA acknowledges, the emission inventory must be “comprehensive, accurate, and 

current” and it must be of “actual” emissions. 78 Fed. Reg. 4804, 4805 (Jan. 23, 2013). To 

begin with, the Tacoma Emission Inventory is not comprehensive. It does not include fugitive 

coal dust emissions. See State Implementation Plan Revision, Tacoma-Pierce County 

Nonattainment Area (Nov. 2012)(SIP submittal) at 42. If the current fugitive coal dust 

emissions are zero because there are no coal trains traveling through the Tacoma nonattainment 

area, then the inventory should say that. Again, this information is important so that everyone 

can accurately and easily determine the increase in PM2.5 emissions from fugitive coal dust 

should coal trains be projected to start coming through the Tacoma nonattainment area due to 

new coal export facilities. 

 Similarly, the SIP submittal says that emission estimates for 2008 and emission inventory 

activity level, as measured in gallons of diesel consumed by locomotives, were provided by 

BNSF, UPRR and Amtrak. However, a comprehensive and accurate emission inventory needs to 

provide the figures for gallons of diesel consumed and emission factors or other calculations 

used in the emissions estimates. Again, this information is critical so that all involved, including 

members of the public and other federal agencies with Clean Air Act general conformity 

obligations, can calculate the increase in emissions in the Tacoma nonattainment area which will 

come should coal export facilities be approved or rail shipment of tar sands oil increase. 

 In conclusion, the SIP submittals emission inventory needs additional information before 

it can be approved. We appreciate the opportunity to provide these comments and look forward 

to EPA requiring this additional information prior to taking final action so that it does not have to 

disapprove this submittal. 

 Sincerely, 

 

 Robert Ukeiley 

 Counsel for Sierra Club