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Potential Coal Routes Through Whatcom County

January 2013

Coal Side Story

Potential Coal Routes Through Whatcom County

by Nicole Brown

Nicole Brown grows with her family at a family-run diversified farm near Acme, WA. She teaches rhetoric and writing for sustainable change at Western Washington University and is passionately involved with SafeGuard the South Fork and Protect Whatcom.

Close to 5,000 unduplicated comments have been submitted to the agencies assigned to write the environmental impact statement scoping document for the Cherry Point coal terminal. And this is a little more than a month before the scoping comment period ends on January 21, 2013.

Most of these comments relate to the construction or operation of the three key facilities identified by Pacific International Terminals (PIT) as necessary for the daily operations of the terminal: a deep-draft wharf with an access trestle, dry bulk materials- handling and storage facilities, and rail transportation access.

Which one of these things is not like the other?

1. Wharf and Trestle

2. Handling and Storage Facilities

3. Rail Transportation Access

Rail Transportation Access:

What Is It, Really?

In the proposed layout for Gateway Pacific Terminal (GPT), a disproportionate amount of space is dedicated to the east and west rail loops, which presumably has something to do with rail transportation access. The proposed layout makes clear just how much GPT’s daily operational plan has to do with trains: staging, unloading, and inspecting. The east and west rail loops, as proposed, have capacity to stage up to eight trains at a time for terminal operations, approximately the same number of trains expected to travel daily to and from GPT. Each of these trains will be 1.5 miles long.

Custer Spur

If permitted, these east and west rail loops would connect with the Custer Spur, requiring new infrastructure to accommodate the number, length, and weight of trains necessary for the daily operations of the terminal. The Custer Spur Improvement Project, as it is called by Burlington Northern Santa Fe Railway Co. (BNSF), is considered to be an “interdependent railway project” to the terminal; therefore, it is included in the project information document. According to PIT no additional “interdependent projects have been identified on the BNSF Railway’s mainline—Bellingham Subdivision, or any other portion of BNSF Railway’s infrastructure.” However, for rail services to operate, track capacity has to be allocated; therefore, all GPT services operated by rail are interdependent to the extent that they share infrastructure.

Interdependent Railway Projects

Studies completed by the Washington State Department of Transportation document that the rail line running along the I-5 corridor is near or at practical capacity. One of the most restrictive choke points is the section of track running next to Samish Bay below Chuckanut Drive. No room is available to double track or otherwise modify that section of track to accommodate the number, length, and weight of trains necessary for the daily operations of the terminal. The expected coal trains per day to and from Cherry Point would double the amount of train traffic between Samish Bay and Cherry Point, for which there is no additional capacity. Therefore, the question of interdependence must remain at the forefront of scoping comments on rail.

The project information document visualizes why the Custer Spur requires new infrastructure to accommodate the expected tonnage of coal being staged on the east and west loops, as well as to manage the required maintenance demands resulting from increased numbers of trains while maintaining current service levels. However, what about infrastructure needs on the main line running parallel to I-5 that the east and west rail loops and Custer Spur feed into? What about the east/west rail proposal in the Whatcom County Comprehensive Plan connecting the eastern Whatcom County foothills rail line to the Custer Spur? And, what about all rail lines that would require new infrastructure to move coal between the Powder River Bain and the east and west rail loops at GPT? Are these interdependent rail projects?

Eastern Whatcom County Foothills

Rail Line

The question of interdependence is apparently on PIT’s mind because they state in their project information document that while the proposal for an east/west rail freight corridor connecting an existing north/south rail line in Eastern Whatcom County to the Custer Spur “appears to be pertinent to the (GPT) project…an east/west rail freight corridor is not being proposed.” (emphasis added)

In 2011 elected officials and community groups in Bellingham, WA recommended that the impacts of proposed coal trains traveling to and from GPT through Bellingham, WA be mitigated by rerouting those trains onto the Eastern Whatcom County Foothills rail line. This rerouting would require trains to cross the Sumas border or require the construction of a new rail link west from Lynden to the main line connecting to the Custer Spur (Map #15, Whatcom County Comprehensive Plan).

Suann Lundsberg, a BNSF official, thoughtfully responded to this idea, stating to The Bellingham Herald that neither alternative to Bellingham appears practical to railway officials. However, in 2012 Lundsberg, speaking honestly to capacity challenges, clarified that BNSF “could not know which line the coal trains would use … we can’t tell you…what the market will bring on lines that are shared by all different commodities.” Will there be significant impacts upon eastern Whatcom County that PIT and BNSF refuse to discuss?  BNSF does have track rights in lower British Columbia. Hundreds of millions of dollars are being spent to improve rail mobility from Abbottsford just north of Sumas that connects with BNSF’s “mail line” to Cherry Point. Furthermore, BNSF has rehabilitated the eastern county line to a state-of-the-art rail through Whatcom County farmlands that parallels much of the Nooksack River.

Jeff Margolis, co-chair of SafeGuard the South Fork, describes GPT as a complex operating system. He goes on to say that it “is simply impossible to detach the transportation component and concomitant impacts from the existence or construction of GPT.  The design of the port itself allows for inferences as to how much can be stored, shipped, and sold. When actual possibilities are acknowledged, then the downstream nodes for environmental assessment become evident.”

Meanwhile … Back in Montana

In 2011, the Ninth Circuit Court of Appeals, in Northern Plains Resource Council v. Tongue River RR, heard arguments of the Surface Transportation Board’s (STB) denial of a request to stop construction of a 130-mile rail project in Montana intended to interconnect to the existing BNSF system at both the north and south ends. The Tongue River Railroad project was to facilitate the transport of coal from Montana to Asian markets. Rather than having the impact of the entire project evaluated as a whole by a single environmental impact statement (EIS), BNSF segmented the project into three separate proceedings before the STB over the past 24 years, which was the basis of the litigation on review by the Ninth Circuit.

The string of environmental impact statements dating back two decades did not consider the railroad as a whole and did not consider the cumulative impacts or economic justification to support the construction of the new rail line to service the Otter Creek coal mine. The Ninth Circuit ruled BNSF could not industrialize an entire agricultural valley for a right-of-way to send coal to Asian markets without taking a careful look at the environmental impacts that would result from the construction of the rail route and its interdependence with the Otter River Mine.

Ted Sturdevant, Director of the Washington Department of Ecology (DOE) announced a similar EIS scoping “gap” regarding GPT’s application. On November 21, 2011, he stated that while DOE does “not consider the statewide rail traffic to be part of the ‘proposal’ itself,” the “full scope of any rail impacts analysis, including geographic scope, will be determined through the public scoping process.” This refusal to link the “full scope of any rail impacts” to the daily operations of the terminal is setting up communities along all rail lines to challenge the adequacy of scoping rail impacts which would not occur but for the construction of GPT.

Take for example the eastern Whatcom County foothills rail line. If it were to be used to get full trains to or empty trains from the Terminal, it would likely require both rail infrastructure improvements and the construction of a new rail line, likely including eminent domain seizures through Whatcom County’s most productive farmlands. Moreover, it would have transformative adverse impacts on the communities, farms, ecosystems, and residents throughout the corridor. The Western Whatcom County rail line is just one illustration of the many communities that would face significant adverse impacts related to rail transportation access if GPT were to be permitted. There are hundreds more. What are the guarantees?

Scoping: Regional and Programmatic

If you are concerned about rail impacts related to the proposed daily operations of the Gateway Pacific Terminal, you have until January 21, 2013, to submit scoping comments asking the co-leads to include in the EIS:

1. The feasibility of using the inland route with or without upgrades or new construction and, if upgrades or new construction were required, what would those be? Also, what would be the environmental and economic impacts of these infrastructure changes on farms, businesses, public funds, and residents? Visit for more information.

2. How increased rail capacity in the Bow to Ferndale bottleneck will be created to handle coal trains traveling to and from GPT? Also, what would be the economic and environmental impacts of these infrastructure changes on parks and recreation, businesses, public funds, and residents? Visit for more information.

3. A regional programmatic EIS (PEIS) that considers cumulative rail impacts of the five proposed coal terminals in Oregon and Washington and considers impacts on all rail communities from the coast to the Powder River Basin. Visit for more info.

Information on how to submit comments is available at:

If you are interested in learning more, please attend the What are you willing to pay?: Rail and Infrastructure Costs Forum at the Unitarian Fellowship on January 8, 7 to 9 p.m. Speakers include: Shannon Wright, CommunityWise Bellingham; David Stalheim, Former Whatcom County Planning Director; Nicole Brown, SafeGuard the South Fork; and Ross MacFarlane, Climate Solutions.

For the truly intrepid, if you address the need for a rail PEIS, please note that the PEIS should be linked to the Tongue River Railroad (TRRR). You can submit the PEIS comment both for GPT and the TRRR. The Tongue River comment phase closes January 11, and those comments must reference environmental filing, Docket No. FD 30186.

Submit online ( or by snail mail (Ken Blodgett, Surface Transportation Board, 395 E Street, SW, Washington, D.C. 20423-0001).

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