From the desk of Dick Cumiskey, President, Sevier County Citizens for Clean Air and Water, Inc
Sevier Citizens for Clean Air & Water submits the following comments on the Draft Environmental Impact Statement for the proposed Alton Coal Mine Expansion.
We appreciate the work that the BLM has invested in preparation of this document but feel there are several omissions and incorrect observations that need to be addressed.
Section 1.2 Purpose There is nothing to show the need for additional coal over what is already being mined in the U.S. Coal-fired power plants are having to be cleaned up under orders from the EPA with the result that many of the older plants are being closed rather that retrofitted with mandated pollution controls. The need for future sources of coal will decrease at an accelerated rate thus permitting existing sources of coal mining to supply the diminishing need.
Under terms of the Energy Policy Act of 2005 there is a statement that energy sources should be diversified. The Western states are already diversifying through the rapid expansion of natural gas and oil drilling in a variety of locations which accomplishes that goal. Included in that diversification is grazing, recreation and a limited amount of mineral extraction.
While the draft EIS states that 82% of the electrical generation in Utah is from coal-fired power plants there is an incorrect assumption that his will continue through 2035. Los Angeles Light & Power has already announced it may not renew its contract with Intermountain Power (IPP) after 2028 when its present contract expires.
Currently, the preferred coal for Utah power plants is from Wyoming because of its lower cost and railhead shipping capabilities.
At present, nearly one half of coal production from the Alton Mine is destined for IPP in Delta, Utah, serving primarily as a back-up service in case of disruptions from other suppliers.
On January 20, the California Public Utilities Commission set new priorities for sourcing electrical power. It reinforced a “Loading Order” with energy conservation and efficiency as the top considerations when planning generation needs. Last on the list is fossil fuel sources.
The US Energy Information Agency statistics show a declining curve for coal consumption in the U.S. This trend has been continuous since the year 2006. Statistics from the same agency also indicate that the percentage of utilization for coal in the electrical generation field is also steadily declining – and at an accelerated rate since 2008.
*Sources: • 1990-1997—EIA, Form EIA-759, “Monthly Power Plant Report,” and Form EIA-867, Annual Nonutility Power Producer Report. • 1998-2000—EIA, Form EIA-759, “Monthly Power Plant Report,” and Form EIA-860B, “Annual Electric Generator Report—Nonutility.” • 2001-2003—EIA, Form EIA-906, “Power Plant Report.” • 2004-2007—EIA, Form EIA-906, “Power Plant Report,” and Form-920, “Combined Heat and Power Plant Report” • 2008-2009 — EIA, Form 923, “Power Plant Operations Report.”
*Source: Energy Information Administration, Monthly Energy Review, March 2010, DOE/EIA-0035(2010/03) (Washington, DC, April 2010).
There is already a significant natural gas transmission system in place, and within reach of IPP, to make it feasible to convert the fuel source for this plant to gas from coal. Current trends in natural gas pricing may accelerate that decision.
1.5 Decisions to be Made Recognizing the proximity to Bryce Canyon National Park and its class 1 air classification, the next best use for the land is one that does not contribute to increased air pollution. This eliminates surface mining as a choice for multiple use while retaining grazing, special status species, visual resources, public health and safety, water resources and wildlife. These remaining resources cover the intent of “multiple use.”
1.8.1 Conformance with BLM Planning Decisions in the KFO RMP do not allow mining where coal unsuitability criteria apply unless the lessee can show that mining would not adversely affect the value that is to be protected.” We believe the value to be protected is the view from Rainbow Point, Bryce Canyon National Park. While no dollar amount can readily be established for this view, it is most certainly, irreplaceable.
4.2.2 Soundscape There is a significant omission here in that sound receptors are listed as being 40 – 50 feet from the roadway. The historic buildings along Main Street, Panguitch are adjacent to the road – less than 40 feet. Sound monitors for Panguitch are not shown in the relevant locations. The greatest impact from noise occurs as the trucks make the right hand turn from the stoplight onto Main St., headed in a northerly direction, and begin to accelerate.
4.2.3 and 18.104.22.168 Visual Resources No KOP’s were established for any location other than Alton. Certainly, a KOP should have been established for observations from Bryce Canyon National Park. There are probably 100 times the viewers on Rainbow Point as there are viewers in Alton.
I drove to Rainbow Point at the southern end of Bryce Canyon National Park to inspect the viewpoint towards the proposed Alton lease. Looking in the southeasterly direction from the point area, the present view is virtually unmarred by any human activity.
Examining the map of the proposed expansion site, it is apparent the expansion will become a prominent feature on the horizon – and not a very pretty one at that.
To reach Rainbow point, one has to drive approximately 20 miles from the visitor’s center through pristine forests and alongside unequaled views of Bryce Canyon itself. The only feature that despoils the extensive view from southwest to southeast is the coal-fired power plant in Page, Arizona. Smoke from the twin exhaust stacks casts a haze over an otherwise unspoiled view.
Other people, standing by the fences along the various viewpoints also noted the distant smoke and decried its presence. None were aware that the same spoilage could possibly occur only nine miles southeast of Rainbow Point. Their first comment was “Why would anyone let that happen?
22.214.171.124 Effects of coal truck traffic on cultural resources
As discussed in the Cultural Resources along the Coal Haul Transportation Route section, the coal haul transportation route under the Proposed Action (see Map 2.4) would pass through the NRHP-listed Panguitch Historic District and would follow Utah Heritage Highway 89, which is part of the Mormon Pioneer Heritage Area. The Panguitch Historic District is significant under NRHP Criterion A for its association with the early settlement of Panguitch and with the subsequent economic development of the area, and it is significant under Criterion C for its intact concentration of historic buildings.
The Mormon Pioneer Heritage Area was established in recognition of the role that Mormon settlement played in the Euro-American colonization of the West, and its purpose includes fostering conservation and interpretation of cultural and natural resources, as well as economic development related to the region‘s heritage. Under the Proposed Action, it is projected that 153 coal truck round-trips per day would occur six days per week over a projected mine life of 25 years. A traffic analysis conducted for this EIS indicates that the portion of US-89 that corresponds to the coal haul transportation route presently experiences average traffic volumes ranging in various locations from approximately 3,600 to 4,100 vehicles per day, of which between 720 and 900 vehicles per day are heavy trucks (Fehr and Peers 2008). Projected total traffic volumes for the year 2020 on US-89 (without the addition of coal trucks) range from 4,400 to 5,850 vehicles per day (Fehr and Peers 2008).
The coal truck traffic that would result from the Proposed Action would be an incremental addition to the existing and projected future traffic volumes. Compared to present levels, it would represent an increase in truck traffic volume of approximately 17%–21%, six days per week. Possible impacts to cultural resources from this incremental increase in truck traffic could include physical damage to historic buildings from traffic generated vibrations, as well an alteration of the integrity of setting, feeling, and association of the Panguitch Historic District and the Utah Heritage Highway 89/Mormon Pioneer Heritage Area.
Alton Coal Tract LBA Draft EIS C
“The California Department of Transportation has presented a technical advisory on transportation-related vibrations (Caltrans 2002). The results in this advisory suggest that neither existing truck traffic nor the addition of further coal truck traffic should physically affect historic buildings. This technical advisory suggests that a peak particle velocity (i.e., velocity of soil particles) of 5.0 millimeters/second (mm/s) is the threshold at which there is a risk of architectural damage (i.e., damage to finish materials) to ?normal dwellings,? such as houses with plastered walls and ceilings. The advisory further suggests that minor structural damage would not occur until peak particle velocities of 10–15 mm/s are reached.
Finally, the advisory recommends that ?ruins and ancient monuments? not be subjected to peak particle velocities of greater than 2.0 mm/s. In contrast to these threshold levels, the advisory reports that the highest measured traffic-generated vibrations from heavy trucks, measured on freeway shoulders at a distance of 5 m (16 feet, five inches) from the center line of the nearest lane, have never exceeded 2.0 mm/s. (Most Panguitch store fronts are about 16 feet from this center lane data point).
Vibration velocity declines exponentially with distance from the source, and because buildings along the coal transportation route are located much farther than 5.0mm/s m from the center line of the closest traffic lane, it is unlikely that buildings along the route would ever experience vibrations that even approach the recommended maximum for ruins and ancient monuments, much less the threshold at which architectural damage to normal dwellings might occur.
Vibration velocity does depend on the road surface, and vibrations could be further minimized by filling potholes and cracks (Caltrans 2002). Although it is unlikely that the additional truck traffic would result in physical damage to historic buildings along the coal haul transportation route, there is perhaps a greater chance that it could adversely affect the integrity of setting, feeling, and association of the Panguitch Historic District, the Utah Heritage Highway 89/Mormon Pioneer Heritage Area, or both. In particular, the increased traffic could result in increases in noise, air pollutants, and traffic congestion in downtown Panguitch and along US-89, thereby adversely affecting the historic feeling of the area for residents and visitors; such impacts are considered in greater detail in the aesthetic resources, air resources, and traffic sections of this document.
Portions of US-89 along the coal haul transportation route currently experience heavy truck traffic of between 720 and 900 vehicles per day. As such, heavy truck traffic is part of the experience of the Panguitch Historic District and the Utah Heritage Highway 89, and the additional volume of 153 trucks per day would represent only an incremental increase against this baseline. In addition, mining is one of the historic uses of the region that was considered in establishing the region as a heritage area, and from this perspective coal truck traffic is not inconsistent with the heritage of the area.”
On January 6, 2012, I spent several hours in one of the historic buildings on Main St. Unfortunately, the coal trucks were not operating that day due to a shutdown at the IPP plant. I had the opportunity to both listen to, and check for vibrations, in the building on Main St. while other heavy trucks were passing through. Most heavy trucks were 18 wheelers of the general cargo type and were probably traveling at greatly reduced capacity, making deliveries to stores, restaurants and other tourist supporting businesses in southern Utah. Trucks accelerating in the north bound direction, the same direction as loaded coal trucks would travel, definitely created harmonic vibrations that could be heard, even though they were below the weight of coal trucks. These coal-haulers weigh in at about 80,000 pounds. In the hours that I spent in the store, only one truck created seismic vibrations that could actually be felt in the unreinforced brick walls. This may have been a loaded truck en route from Phoenix to Salt lake City.
Main St. in Panguitch is like a canyon. The sounds and vibrations bounce from one building to a façade across the street and back. This Main Street historic district is largely built of unreinforced brick and mortar, making it more vulnerable to damage from both sound waves and seismic activity through the road bed.
There is a need to evaluate this potential damage while coal haulers are in operation, preferably with some type of seismic measuring instrument. The studies by CALTRANS only refers to truck traffic along a freeway which is likely to have a superior road base to Main St. in Panguitch and reflects a condition where heavy trucks are not starting from a standstill as they would be from the stoplight in Panguitch. The freeway studies do not evaluate activity in a “canyon” type environment.
126.96.36.199 SUMMARY OF EFFECTS ON CULTURAL RESOURCES UNDER THE
“The incremental increase in truck traffic through the Panguitch Historic District and along the Utah Heritage Highway 89 that would occur under the Proposed Action would likely not cause physical damage to historic buildings along the route. However, it likely would have some adverse effect on the integrity of setting, feeling, and association of these resources.”
See the comments above as we believe the present conditions have not been properly measured and evaluated.
Quoted from Dave Rust – a life in the Canyons, Frederick H. Swanson, 2007, page 242
Clarence Dutton, trying to describe these scenes in his 1880 Report on the Geology of the High Plains of Utah, fell back to quoting the pioneer geologist J.S. Newberry, who had investigated the region in 1859: “Though valueless to the agriculturist, dreaded and shunned by the emigrant, the miner and even the adventurist trapper, the Colorado Plateau is to the geologist a paradise. Nowhere on the earth’s surface, so far as we know, are the secrets of its structure so fully revealed as here.” Rust could take pleasure in showing these vistas to those who had never experienced the great openness of the southwest.
What held (Dave Rust’s) interest most was the simple act of looking at a landscape. In the popular imagination this was often derided as merely viewing scenery, but Rust saw something in the distant view that, he felt, could enlarge one’s life. Like many who have felt a strong connection to the natural world, Rust believed that the quest for magnificent vistas could have a profound influence on the human spirit. He addressed this theme in a 1929 article for Improvement Era titled “Fleeing to Zion – For Scenery.”
“What is the value of scenery?” His answer drew on his wide reading. “In one of the oriental Bibles it is recorded that if we have but two cakes we should sell one and buy a narcissus; for the cake simply feeds the body while the narcissus feeds the soul. Perhaps these many travelers are feeding their souls. Perhaps the sunshine of open spaces has destroyed some of the germs of prejudice. It is difficult to measure the influence of classic literature or classic paintings or classic music – or classic scenery.” Here was Rust’s mature realization that our reaction to beautiful places has a moral aspect, a quality the visitor must cultivate.”The man who climbs a mountain or crosses a desert or looks into a deep-carved canyon,” he continued “should return from such experiences with genuine values; . . .”
Dave Rust was born in rural Utah, grew up near Caineville, went to school in Richfield and spent most of his married life in Kanab from whence he traveled extensively and guided paying customers throughout the southern tier of Utah for four decades. He was a visionary in explorative excursions long before they became popularized as “eco-tourism.”He had a great appreciation for what the landscape was, not what it could be ravaged for.
Sevier Citizens for Clean Air & Water recommends you heed the advice of Dave Rust and reject the application of Alton Coal LLC
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