A Marginal Proposition

A big 2013 news item in Whatcom County was the determination of the scope of the Environmental Impact Statement (EIS) for the proposed Gateway Pacific Terminal (GPT) at Cherry Point. Within that scope, an eye-opening line item was the inclusion by the Washington Department of Ecology (DOE) of greenhouse gas emissions (GHG) from the end use of combusting the coal that will be exported by the terminal.

On the face of it, this scope item is a game changer. The proposed 48 million metric tons of coal to be exported per year will result in at least 86 million metric tons of CO2 emissions per year — adding up to gigaton levels of emissions over a potential operating period of decades for the proposed terminal.

Those emissions dwarf planned GHG emission reduction targets of 30 million metric tons per year for the entire state of Washington by 2035. As a state, we may achieve those reductions (at considerable cost) and then see any gains wiped out — by a factor of almost three.

If the entire amount of GHG emissions downstream of GPT is considered in permit decisions made by state of Washington agencies, it is hard to imagine that state-level permits will be issued for the terminal. Approving the coal terminal would demonstrably confound state GHG reduction policies, which are codified into Washington state law. Absent state permits, there will be no terminal.

This may be one reason that pro-terminal forces have concentrated their ire on this specific part of the EIS scoping decision. The November letter by former Attorney General Rob McKenna, stating that [Congress] “has not authorized states to regulate interstate commerce in relation to climate change,” is just one part of a larger campaign to de-legitimize the DOE decision.

However, another question looms large: whether the total emissions of GHG’s from combustion of the coal will be considered, or whether the EIS will use a calculated value for marginal emissions, compared to some other potential future.

For example, the EIS could model a scenario where, absent the coal export terminal, Chinese industries and power plants purchase replacement coal from other sources; in an extreme case, this model could project that all of the coal from GPT would be replaced, resulting in a calculated marginal emissions of — you got it — zero.

This would be just a theory, except that such a finding — marginal zero emissions for a large hydrocarbon project — was made by the hotly-contested EIS for the Keystone XL Pipeline. That EIS based its marginal zero finding on the theory that, if Keystone XL was not built, other pipelines (which currently do not exist and have not been permitted) would be used instead, potentially together with rail transport, to bring the additional quantities of tar sands oil to the market, with the same resulting GHG emissions.

In the case of GPT, an EIS finding of zero marginal GHG emissions could be a worse result than DOE not considering GHG emissions at all. Such a finding would allow terminal proponents to maintain that these emissions had been considered, as opposed to being ignored.

Several economic studies have found that the additional coal supply provided by GPT will reduce prices and thus increase coal use and resulting GHG emissions. The marginal zero scenario is not reasonable.

Hey — what just happened?

The moment we start looking at studies that consider a modeled marginal effect of GPT on GHG emissions, we implicitly accept the concept that marginal emissions are a reasonable course of inquiry. And that’s wrong, no matter what quantity of marginal emissions we may determine.

Here’s why, specifically in connection with GPT: the coal terminal is intended to meet future increases in demand for coal in China, which means that those alleged replacement coal sources, whether domestic to China or imports, don’t yet exist. So, any marginal emission scenario is based on, and accepts, the creation of new coal sources for newly-built coal power plants.

In light of everything that is known about required reductions in GHG emissions, and also considering federal and state policies, any EIS that accepts the certainty of expanded coal use is, put simply, wrong. It creates a low bar for any proposed project — such a proposal must only demonstrate that, out of the set of potential projects that lock us into worsened climate effects, the specific proposal is no worse than the others that may be on the table.

More generally, the word is “beware” — of any process that presumes continued degradation of the environment and treats that assumption as the starting point of the evaluation. In today’s world, that isn’t good enough. The starting point for any evaluation must be the better of: 1) The current status, or 2) legally-required improvements to the situation, such as species recovery requirements under the Endangered Species Act, or required GHG emission reductions.

Sometime in the future, we will have the opportunity to comment on the findings of the GPT EIS, whatever those findings may be. If the EIS uses any value other than the total GHG emissions downstream of GPT, it will be wrong. For your planning purposes you can count on me reminding any and all readers of this.

Meanwhile, I encourage everyone to take to heart the core idea that we cannot accept increased degradation of our environmental resources as an acceptable condition of any decision faced by our community or region, whether it is a coal terminal or anything else.

• EIS Scoping news release by the three co-lead agencies: http://www.eisgatewaypacificwa.gov/sites/default/files/content/files/EIS-PressRelease-73113.pdf#overlay-context=resources/press-room

• Rob McKenna letter re: the coal terminal https://doj.mt.gov/wp-content/uploads/AGLetter-Longview_Nov2013.pdf and The Seattle Times coverage of it: http://seattletimes.com/html/localnews/2022308911_mckennacoalxml.html

• Keystone XL EIS, Climate Change Section: http://keystonepipeline-xl.state.gov/documents/organization/205563.pdf

• Reference for finding that increased exports will increase coal consumption in China: http://www.sightline.org/research/greenhouse-gas-impact-of-exporting-coal

• For WA state GHG reduction targets and also emission factors for Powder River basin coal, see the May 2013 issue of Whatcom Watch, References section at the end of this story: http://www.whatcomwatch.org/php/WW_open.php?id=1552