Kalama Manufacturing and Marine Export Facility Second Supplemental EIS

4777 Results

Sort:

Comment From: Larry Tyrell

10/14/20 @ 5:00 PM
Attachments:

Comment From: Carolyn Laulainen

10/14/20 @ 5:00 PM
Attachments:

Comment From: Thomas Gordon

10/14/20 @ 5:00 PM

If the proposed Kalama Methanol Refinery is built, a storage tank rupture would release a huge amount of greenhouse gases.

The proposed Kalama Methanol refinery is scheduled to be built with faults and suspected faults nearby, subject to earthquakes.

"...↓

The proposed Kalama methanol refinery would be built on fill material that is rated as highly susceptible to liquefaction and thus suffer higher damage from an earthquake. The Kalama area has at least one fault as shown by a 1.8 magnitude earthquake on April 13, 2020, 0.2 km from Kalama. This earthquake was at a depth of 0 km. A strong surface earthquake can cause more damage than one at depth. While this was a relatively weak earthquake, a major fault could be here with the potential for a stronger, damaging earthquake in the future.

A major earthquake could rupture methanol storage tanks with faults relatively close to the surface where the plant would be built. The release of the stored methanol could be catastrophic, especially if ignited by a spark from downed power lines. A huge amount of pollution and green house gases would subsequently be released.

The proposed Kalama methanol refinery, if it exploded, would pose a grave risk to the town of Kalama and add to the pollution and CO2 for our planet. This refinery should not be built.

No attachments

Comment From: Marianna Grossman

10/13/20 @ 7:08 AM
September 22, 2020

Kalama Manufacturing and Marine Export Facility Public Hearing testimony

Dear Mr. Zenk:

Thank you to you and your Ecology Dept. colleagues for setting up hearings. Here is the text of what I presented verbally this evening.

I am Marian...↓
The State of Washington must meet its climate goals and set an example for other states so that humanity has a chance of limiting global warming to 1.5C. We can see that our current trajectory is already resulting in catastrophic fires, storms, smoke and enormous social, environmental and economic costs.

I am troubled by the unnecessary conflict expressed today between good paying jobs and human and environmental health and well being.

One example of a community that shifted from fossil fuels to locally produced bio and renewable energy is G�ssing a small town in Austria, near the Hungarian border. Now they produce high quality jobs in clean energy production, technology research and innovation. They even had to build a hotel to support visitors coming to study their transformation and the technology and economic models they innovated. We should do this in our region too. We can increase forestry and agricultural jobs as well as technology and hospitality jobs by investing in all of our futures.

The initial investment in Gussing's transformation came from a combination of sources: the EU, the Austrian Department of Environment, local government and private investors.

The region went from out-migration for work and spending on fossil fuels to innovative new businesses, including an eco-industrial system where waste saw dust from the veneer/furniture plant is used to power heat for the noodle factory which uses eggs from local chickens and creates zero CO2 noodles, as one example.

Here is information about G�ssing achieving zero GHG emissions.
https://www.100-percent.org/gussing-austria/

Here is more information about the technology and economic impact of their regional transformation.
https://ec.europa.eu/regional_policy/en/projects/austria/new-formula-for-renewables-revolutionises-gussing

To quote the European Union website report this has been a profitable investment:
"The plant gets around 15 euro cent per kWh for its electricity. This is much less than the price, around 25 euro cent, being paid by domestic consumers in the area. It is estimated that this plant, together with another wood-fired heating system with a capacity of 42 MW, means that �18 million stays in the district each year that would otherwise have leaked out. This represents massive return on investment.
The availability of cheap heat (30% cheaper) has led to over 1,000 new jobs being created in and around the town, including 100 in a new office building on an industrial estate which houses the European Centre for Renewable Energy. This employs 12 people itself and the other people renting space in the building are mostly from companies or consultancies to do with renewable energy. One of the centre's activities is arranging visits for the increasing number of visitors who come to see what G�ssing has done, an activity which itself creates employment in hotels and restaurants.
By making the switch from fossil fuels to renewables, the people of G�ssing are now more than self-sufficient for electricity and heat."
They raise agricultural crops for biomass as well as using cultivation techniques to remove excess vegetation from surrounding forests and strategically located solar energy generation, as well.
This transformation was designed to lift the well-being of all the residents of this small town and rural community. We should do the same in our own communities.

Sincerely yours,

Marianna Grossman
Portland, OR

No attachments

Comment From: Thomas Gordon

10/12/20 @ 5:00 PM
NWIW plans to use part or all of the methanol it hopes to produce as fuel in China. However, most of China's power comes from coal-fired plants now.

As reported in Carbon Brief, March 24, 2020, China, with more than half of it's coal -power firms losi...↓

"Looking at the energy situation shows the China's network operator, State Grid, and the industry body, the China Electricity Council, are pushing for hundreds of new coal-powered power plants to be built. "And a recent update to the "traffic light system" for new coal-power construction signaled further relaxation of permitting." Even now, China, the world's largest emitter, who over took the EU in 2003 and the US in 2005, is putting out nearly a quarter of global green house emissions.

Also, China is pushing ahead on renewables. The result is over-capacity,built on purpose. China is working to keep its options as open as possible in the future.

China's "economic miracle" has seen the country become the world's second-largest economy and pulled nearly a billion people out of poverty. But this progress has been built on a boom in energy from coal, meaning China has also become the world's largest carbon polluter by far.

China's CO2 emissions increased again by around 2% in 2019, based on recently released official economic data, and 65% of the annual growth in energy consumption came from fossil fuels.

Coal is the most carbon-intensive fossil fuel and still accounted for 57.7% of China's energy use in 2019, the data shows. Coal plants, which burn approximately 54% of all coal used in the country, provide 52% of generating capacity and 66% of electricity output - down from a peak of 81% in 2007.

Coal-fired power capacity grew by around 40 gigawatts (GW) in 2019, a 4% increase, and a pick-up from the past two years. As a result, the coal fleet's average utilization rate fell further, to below 50% on average.

Against this backdrop, there is already heated debate - as outlined below - over China's 14th FYP, (five year plan), which will set national targets and priorities for the next five years. The energy targets that will be set by the plan mean it will be a crucial document for global efforts to tackle climate change.

Under the existing 13th FYP, coal power capacity is capped at 1,l00GW. Separate targets aim to raise the share of China's energy mix that comes from non-fossil sources to 15% by 2020. More detailed development plans set out indicative targets for sectors such as renewable energy. (Solar has significantly exceeded the relatively low indicative target that was set five years ago.)

Targets of a similar nature are likely to be set as part of the overarching 14th FYP, due to be agreed on early next year. Further details will  then be set  out in sectoral plans over the following year. The power­ sector plan, which could include targets for the growth of most generation options - but particularly renewables - might be expected during winter 2021 -22, based on previous cycles.

The stakeholder consultancy, scoping and drafting for the power-sector plan has already been started within the government system, with different academic organizations and think tanks tasked with producing research to support the process.

China's coal-power overcapacity dates back to the 12th FYP. This was formulated in the early 2010s as part of the largest economic stimulus programme in history, launched in response to the global financial crisis. It targeted a huge expansion in coal mining and coal-fired power generation.

Then, from 2014, the authority to approve new coal­ fired power plants was transferred from the central government to the provincial level, in a drive to cut red tape.

Many local governments jumped at the opportunity to prop up GDP and create demand for locally mined coal with new power projects, leading to around 210 projects with a total capacity of 169GW being rubber-stamped in less than a year.

This surge of new projects came as demand for coal­ fired electricity declined from 2013-2015, apparently catching the central government by surprise. It then moved to curtail approvals and suspend already permitted pro je cts.

China's economic system is based on abundant and cheap capital being made available to the stat e­ owned sector with little concern for economic viability, as long as the investments made are broadly aligned with the five-year plans.

This system can mobilize vast amounts of resources, but is prone to over-investment, as companies and local governments use capacity expansion to boost GDP and gain market share. The planning machinery limits overcapacity with control policies - with varying levels of success.

Many experts and industry bodies argue for a move away from top-down targets and controls, to investment driven by market forces. However, the spending needed to fuel a new stimulus program can only be mobilized if investment is directed at the behest of the state, rather than the market -  as a rule, China does not fund stimulus with on-budget spending, but by directing state-owned enterprises and commercial banks to spend more. In these circumstances, lack of controls on capacity additions runs a high risk of over-investment .

For example, efforts to control overcapacity might be vulnerable to the political priority of boosting investment spending to reach economic targets. An indication of this was the loosening of "traffic lights" for new coal-plant approvals, published by the National Energy Administration in February.

The traffic light policy was first introduced in January 2017 to prevent provinces with overcapacity from permitting new projects. A year ago, however, 21 of China's 31 provincial grids included in the policy were given a "green light". Last month this increased to 25."

Thus, there is no pressing incentive to build methanol-burning plants. However, one incentive is to use resources outside China in order to save internal resources.

There is no reason for us to build this plant just as a hedge against the future for China. The result for us is destroyed land and forests to get at the gas by fracking in Canada and the US. Leakage of methane will increase as more methane is pushed to Kalama through aging gas lines, some SO to  60 years old, the projected life times of some of these lines.

Plus, our electricity will be used to refine the methane into methanol through electric lines that created pollution in their manufacture and placement. The refining of methanol itself creates millions of tons of pollution. Lastly, transporting the methanol down the Columbia River and across the Pacific to China will create more pollut ion.

If this refinery is not built, all these green house gases won't be created either.

Please do not issue the permits for this refinery.
Attachments:

Comment From: Roger Brindle

10/12/20 @ 5:00 PM
Attachments:

Comment From: Leigh McKeirnan

10/12/20 @ 5:00 PM
Attachments:

Comment From: Thomas Gordon

10/09/20 @ 5:04 PM
The leakage rate in the SSEIS does not reflect the conclusions in other studies which go up to 3%.Some of the factors which influence this rate include the number of leaks in the US natural gas distribution system.

The American Chemical Society in Env...↓

A National Estimate of Methane Leakage from Pipeline Mains in Natural Gas Local Distribution Systems

We estimate methane emissions from U.S. local distribution natural gas (NG) pipes using data collected from an advanced mobile leak detection (AMLD) platform. We estimate that there are 630,000 leaks in U.S. distribution mains...

While this article does not address the gas line to Canada specifically, it shows that gas line leaks are wide spread.

Also, the following article addresses the pipes themselves:

Supporting information for a national estimate of methane leakage from pipeline mains in natural gas local distribution systems



Zachary D. Weller,�, Steven P. Hamburg,! and Joseph C. von Fischer�

Department of Statistics, Colorado State University, Fort Collins CO USA

Our leaks per mile analysis (Section 3 of the main text) indicated that activity factors

.212 are a function of both pipe material and pipe age. Furthermore, activity factors increase

.213 exponentially with age. Current PHMSA reporting does require the reporting of the join

.214 distribution of pipeline age and material, nor does it report the exact age of pipe more than

.215 80 years. Requiring utilities to report these data would improve our estimates of the total

.216 number of leaks and thus the total emissions from local distribution systems.

211 Our leaks per mile analysis (Section 3 of the main text) indicated that activity factors

.212 are a function of both pipe material and pipe age. Furthermore, activity factors increase

.213 exponentially with age. Current PHMSA reporting does require the reporting of the join

.214 distribution of pipeline age and material, nor does it report the exact age of pipe more than

.215 80 years. Requiring utilities to report these data would improve our estimates of the total

.216 number of leaks and thus the total emissions from local distribution systems.

Activity refers to the leakage

Types of gas lines and the pressure in them affect the leakage rate too.

These pipelines�including flowlines, gathering lines, transmission lines, distribution lines, and service lines�carry gas at varying rates of pressure. The higher the pressure of gas in a pipeline, the more potentially dangerous an accident with that pipeline could be.

Pipelines usually are buried underground, and pipeline markers do not always sit directly above the pipelines.

Flowlines

Flowlines connect to a single wellhead in a producing field. Flowlines move natural gas from a wellhead to nearby storage tanks, transmission compressor stations, or processing plant booster stations. Flowlines are relatively narrow pipes that carry unodorized raw gas at a pressure of approximately 250 pounds per square inch (psi).

Typically, they are buried 4 feet underground and can corrode, especially if they are carrying wet gas. They also are prone to methane leakage. According to the EPA, "methane leakage from flowlines is one of the largest sources of emissions in the gas industry."

Gathering Lines

Gathering lines collect gas from multiple flowlines and move it to centralized points, such as processing facilities, tanks, or marine docks. Gathering lines are medium steel pipes (usually less than 18 inches in diameter) that carry unodorized, raw gas at a pressure of approximately 715 psi.

Typically, gathering lines are buried 4 feet underground and carry corrosive content that can affect pipeline integrity within a few years.

Transmission Pipelines

Transmission pipelines carry natural gas across long distances and occasionally across state boundaries, usually to and from compressors or to a distribution center or storage facility. Transmission lines are large steel pipes (usually 2 to 42 inches in diameter; most often more than 10 inches in diameter) that are federally regulated. They carry unodorized gas at a pressure of approximately 200 to 1,200 psi.

Transmission pipelines can fail due to seam failures, corrosion, materials failure, and defective welding.

Distribution Pipelines

Distribution pipelines, also known as "mains," are the middle step between high-pressure transmission lines and low-pressure service lines. Distribution pipelines operate at an intermediate pressure. This type of pipeline uses small to medium pipes (2 inches to 24 inches in diameter) that are federally regulated and carry odorized gas at varying pressure levels, from as little as 0.3 psi up to 200 psi.

Distribution pipelines typically operate below their carrying capacity and are made from a variety of materials, including steel, cast iron, plastic, and occasionally copper.

Service Pipelines

Service pipelines connect to a meter that delivers natural gas to individual customers. Service pipelines are narrow pipes (usually less than 2 inches in diameter) that carry odorized gas at low pressures, such as 6 psi. Service pipelines typically are made from plastic, steel, or copper.

Therefore, the leakage rates are at best estimates so the higher values are closer to the actual amounts lost due to limits in testing, the distances the lines travel, and the size and pressures in these lines.

This refinery contributes to the total green house gases more than can be estimated with the low figure in the SSEIS.

Please deny this permit and the refinery.

No attachments

Comment From: Wild Idaho Rising Tide (Helen Yost)

10/09/20 @ 5:03 PM
Please consider in your deliberations the attached WIRT Comments on the Second Supplemental Environmental Impact Statement for Northwest Innovation Works' Kalama Manufacturing and Marine Export Facility.
Attachments:

Comment From: Jennifer Vinnard

10/09/20 @ 4:57 PM
As this is the last opportunity to comment, I'd like to reiterate the facts that have so many of us concerned, some have no bearing on your decision, but they're vital pieces of the risks outweighing any possible rewards.

Knowing that in the event of ...↓
NWIW has fought against providing unbiased and accurate data, threatening Ecology to try and force approval of the permit, and has been caught in lies about their intentions for the methanol produced. NWIW's PowerPoint presentation to investors made it crystal clear that fuel is their objective, despite their claims that this refinery would be a methanol to olefin's ONLY plant, that zero amount would be used for fuel, they lied to everyone's face, and yet Ecology has only calculated a scenario of 40% methanol used for fuel..please calculate 100%, or at least 75%, that is a more likely scenario than 40% given China's projected use of methanol for fuel in automotive, shipping, industrial and more fuel applications, listed in the information they used to snag investors.
The speculation that this refinery would displace coal use in China comes with absolutely zero evidence to support the claim,there is however plenty of proof that the opposite is true. A recently discovered document exposed China's 5yr economic plan is to build coal power plants in each province by 2023,the Chinese Government approved $6.7 billion in new coal mining sites just last year, their consumption and demand has only increased each year, including their coal import amounts, and their newly signed plans to achieve carbon neutrality by 2060 does not mean a reduction in carbon/ghg emissions, rather an attempt to emit the same amount of good to bad..so they can emit high amounts of ghg emissions and still give the appearance of trying to help reduce ghg emissions.
With a minimum of 4.6 million tons of ghg emissions per year being pumped into our air, water and land, we will be inundated with a constant barrage of dangerous chemicals entering our lungs every day..how is this in any way acceptable?

Being built atop dredged topsoil, in an area already subject to potential liquifaction during an earthquake, the risk of failure is amplified.
The pipeline, which is already strained, will use more natural gas per day than all of Washington's gas power plants combined..causing shortages and price increases for customers, locking out future potential businesses, and running high risks of ruptures due to the landslide prone hills it's built on, as well as the lateral pipeline to the plant..the pipeline has already ruptured twice in recent years due to land movement..it will continue to occur, not to mention the effects on our electrical grid!
The promise of local jobs was used to lure residents support, those who thought that meant Cowlitz County, but the reality is that few people living here would actually be able to obtain work there. NWIW has said 10-20% of workers would be local, and the new NWIW/POK lease states a minimum of 80 workers would be employed there..that's 8-16 people who live within an hour and a half drive, the rest will be relocated here from China, Texas and other states with methanol refinery's.
A projected state tax profit of $40 million a year, with $143 million in write offs and tax breaks..that's not worth the risks..we make 10X that on cannabis taxes, without all the negative consequences! My family and thousands of others are adamantly opposed to this refinery, will move if it's approved, we can't watch our amazing town be destroyed by this pollution nightmare. Please deny the permit, let us shed this agonizing stress from our lives..we can and will find better industries for truly local jobs without all the negative impacts. Thank you for your time, please, please deny this permit! Sincerely the Vinnard family, Kalama.
No attachments

Comment From: Enji Cooper

10/09/20 @ 4:53 PM
I oppose the Kalama Methane Refinery.

There are better ways to produce longterm jobs using green energy, as opposed to short term jobs using fracked methane which has a high capacity to pollute the environment when transported over long pipelines.

I op...↓
No attachments

Comment From: Thomas Gordom

10/09/20 @ 4:49 PM

The leakage rate in the SSEIS does not reflect the conclusions in other studies which go up to 3%. Some of the factors which influence this rate include the number of leaks in the US natural gas distribution system.
The American Chemical Society in E...↓
A National Estimate of Methane Leakage from Pipeline Mains in Natural Gas Local Distribution Systems

We estimate methane emissions from U.S. local distribution natural gas (NG) pipes using data collected from an advanced mobile leak detection (AMLD) platform. We estimate that there are 630,000 leaks in U.S. distribution mains...

While this article does not address the gas line to Canada specifically, it shows that gas line leaks are wide spread.

Also, the following article addresses the pipes themselves:

Supporting information for a national estimate of methane leakage from pipeline mains in natural gas local distribution systems

(

Zachary D. Weller,�, Steven P. Hamburg,! and Joseph C. von Fischer�
Department of Statistics, Colorado State University, Fort Collins CO USA

Our leaks per mile analysis (Section 3 of the main text) indicated that activity factors (
. 212 �are a function of both pipe material and pipe age. Furthermore, activity factors increase (
. 213 �exponentially with age. Current PHMSA reporting does require the reporting of the join (
. 214 �distribution of pipeline age and material, nor does it report the exact age of pipe more than (
. 215 �80 years. Requiring utilities to report these data would improve our estimates of the total (
. 216 �number of leaks and thus the total emissions from local distribution systems.

211 �Our leaks per mile analysis (Section 3 of the main text) indicated that activity factors (
. 212 �are a function of both pipe material and pipe age. Furthermore, activity factors increase (
. 213 �exponentially with age. Current PHMSA reporting does require the reporting of the join (
. 214 �distribution of pipeline age and material, nor does it report the exact age of pipe more than (
. 215 �80 years. Requiring utilities to report these data would improve our estimates of the total (
. 216 �number of leaks and thus the total emissions from local distribution systems.
Activity refers to the leakage

Types of gas lines and the pressure in them affect the leakage rate too.

These pipelines�including flowlines, gathering lines, transmission lines, distribution lines, and service lines�carry gas at varying rates of pressure. The higher the pressure of gas in a pipeline, the more potentially dangerous an accident with that pipeline could be.

Pipelines usually are�buried underground, and pipeline markers do not always sit directly above the pipelines.

Flowlines
Flowlines connect to a single wellhead in a producing field. Flowlines move natural gas from a�wellhead to nearby storage tanks, transmission compressor stations, or processing plant booster stations.�Flowlines are relatively narrow pipes that carry unodorized raw gas at a pressure of approximately 250 pounds per square inch (psi).

Typically, they are buried 4�feet underground and�can corrode, especially if they are carrying wet gas. They also are�prone to methane leakage. According to the EPA, "methane leakage from flowlines is one of the largest sources of emissions in the gas industry."

Gathering Lines
Gathering lines collect gas from multiple flowlines and move it to centralized points, such as processing facilities, tanks, or marine docks.�Gathering lines are medium steel pipes (usually less than 18 inches in diameter) that carry unodorized, raw gas at a pressure of approximately 715 psi.

Typically, gathering lines are buried 4�feet underground and�carry corrosive content that can affect pipeline integrity within a few years.

Transmission Pipelines
Transmission pipelines carry natural gas across long distances and occasionally across state boundaries, usually to and from compressors or to a distribution center or storage facility.�Transmission lines are large steel pipes (usually 2 to 42 inches in diameter; most often more than 10 inches in diameter) that are federally regulated. They carry unodorized gas at a pressure of approximately 200 to 1,200 psi.�

Transmission pipelines can fail due to seam failures, corrosion, materials failure, and defective welding.

Distribution Pipelines
Distribution pipelines, also known as "mains," are the middle step between high-pressure transmission lines and low-pressure service lines. Distribution pipelines operate at an intermediate pressure.�This type of pipeline uses small to medium pipes (2 inches to 24 inches in diameter) that are federally regulated and carry odorized gas at varying pressure levels, from as little as 0.3 psi up to 200 psi.

Distribution pipelines typically operate below their carrying capacity and are made from a variety of materials, including steel, cast iron, plastic, and occasionally copper.

Service Pipelines
Service pipelines connect to a meter that delivers�natural gas�to individual customers.�Service pipelines are narrow pipes (usually less than 2 inches in diameter) that carry odorized gas at low pressures, such as 6 psi.�Service pipelines�typically are made from plastic, steel, or copper.

Therefore, the leakage rates are at best estimates so the higher values are closer to the actual amounts lost due to limits in testing, the distances the lines travel, and the size and pressures in these lines.

This refinery contributes to the total green house gases more than can be estimated with the low figure in the SSEIS.

Please deny this permit and the refinery.

(

((

No attachments

Comment From: Anita J. Thomas

10/09/20 @ 4:46 PM
My friend of blessed memory, Bill Brake, worked in the petrochemical industry for 35 years, gaining considerable expertise in the workings of oil and gas facilities. In his retirement, he often gave expert testimony concerning such facilities. In J...↓

Not long before Bill's untimely death in 2017, he was able to examine the proposal for the NWIW facility in Kalama and noted a host of failings that made the whole project a disaster in the making. Even if the proposed facility worked as designed, it would produce unconscionable levels of greenhouse gases as inevitable collateral damage, but greenhouse gas emissions would explode astronomically in case of a tragic accident. The intervening time since Bill's death has seen changes to the NWIW proposal and three EIS statements that leave a fatal flaw at the heart of this facility untouched. The core of the problem is a disastrous disregard for basic safety built into the very concept and design of the proposal. As I am not the expert that Bill Brake was, I can list only the most rudimentary and egregious errors that seem most dire to me.

First, there are daunting external factors that are already accidents waiting to happen. To start with, the proposed site location is on shoreline fill and thus a liquefaction zone in case of significant earthquakes. The risk of ruptures, explosions, and fires is unacceptably high, including attendant increase of GHG emissions.

Next, there is the size of the project, with its massive use of Columbia River water and
heating of the river. Fish kills due to overheated water would cause methane and other noxious gas emissions. Further, there is the terrifying risk of a BLEVE (Boiling Liquid Explosive Vapor Event). Even if a BLEVE were triggered by some unaccountable circumstances, such an accident would launch a breathtaking chain of destruction, due purely to the laws of physics. If the BLEVE were released at speed into the former Trojan Nuclear Site, the resultant multiplication of GHG emissions would be incalculable, not to mention disastrous to the people and community affected. Looming over any major accident is the proximity of the railroad, I-5, the community of Kalama itself, and the surrounding forest. In the case of the trees, fires would more than double GHG emissions, since the trees would be transformed from absorbers of CO2 into emitters of it in the course of combustion.

If the external factors just enumerated were the primary problem, that should be more than enough to stop the project. However, the deeper, inherent problem of human error is all but guaranteed to bring on one or more of the above problems because of the incomprehensible disregard for safety in the design and execution of this proposed refinery. To wit:
Northwest Innovation Works, LLC has no refinery employees.
NWIW has no active license with L and C.
NWIW has no income from methanol sales.
NWIW has no assets.
NWIW has no documentary evidence of credentials.
NWIW has no experience building or operating a methanol refinery. (Components would be assembled in China and shipped over here.)
NWIW has no EPA approval for the ULE technology which is supposed to decrease GHG emissions. No methanol refinery has ever used both ULE and ZLD technology together.

All the above is horrifying enough, but the staggering incompetence outlined here goes even further. First, the design is experimental. There is only one similar refinery in the world, in Australia, It is not run by NWIW which has no experience with it. Second, according to Bill Brake a facility handling the capacity proposed by NWIW would require a minimum of 500 square acres; the Kalama proposal is for about 98 square acres. Texas has a century of experience with refineries and has come to this well established practice from hard lessons won from previous gas refinery explosions.

So NWIW is proposing to build the world's largest fracked-gas-to-methanol refinery using an untested, experimental design on the equivalent of a postage stamp sized tract of unstable fill half a mile from a nuclear storage facility, with no experience in building or operating a methanol refinery, no refinery employees, no credentials, no assets, no income from methanol sales, no L and C license, and no EPA approval for one of their GHG removal technologies, and no president anywhere for using their two GHG removal technologies together. How in the name of all good common sense has the NWIW proposal possibly made it this far in the process?

The decision you make surely includes an economic cost benefit analysis, weighing the projected jobs in Kalama against possible risks to the health, safety, and general welfare of the local area. It is incumbent on you to do due diligence, weighing the true magnitude of the genuine risk involved against the largely illusory jobs promised.

There is a precedent here which provides a cautionary tale. When the Alaska Pipeline was proposed, Alaskans were promised jobs. However, once that pipeline was approved, most of those jobs went to experienced workers from Texas and Oklahoma, one of whom was my father, a Texan. In an NWIW hearing about 4 years ago, two of the people in the crowd that I talked to were from Texas. Our local people would hardly have a fair chance against experienced workers here.

Finally, the cost benefit analysis should contain liability insurance considerations. I have found no figures available on the proposed liability limits. It is hard to imagine any adequate insurance for the proposed refinery. I fear Washington taxpayers would be on the hook for whatever shortfall there would be. In the case of the gas refinery explosion at Phillips, Texas, the loss of the town's economic base was devastating to its residents. The loss to Kalama and its surroundings would be indescribably worse, possibly on the order of the recent explosions in Beirut, Lebanon. I feel sure I would feel such an explosion at Kalama here in Vancouver. Please, please deny the Shoreline Permit.

This testimony is dedicated to the memory of William Brake.
No attachments

Comment From: Sally Keely

10/09/20 @ 4:34 PM
KMMEF will emit 62 tons of particulate matter annually. Particulate matter is known to carry Sars-Cov-2 virus (COVID-19) per https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7345938/. Areas of high particulate matter also have high rates of coronavirus i...↓
No attachments

Comment From: Jennifer Johnson

10/09/20 @ 4:33 PM
Attachments:

Comment From: Linda Horst

10/09/20 @ 4:26 PM
The following three security issues present significant potential risks not only in Kalama and Cowlitz County, but to our state as well. The common thread tying the three together is foreign ownership and management of the proposed KMMEF refinery in ...↓

Before discussing the three risk factors, I will clarify who owns and would manage the NWIW refinery.

NWIW LLC (WA Secretary of State�no active L&I license�no covered employees) is majority or wholly owned by a U.S. company called Pan-Pacific Energy Corp. (PPE) Delaware LLC. This corporation is registered with the WA Secretary of State�UBI 603 371 412 as a Foreign Profit Corp. with 11-20 workers. PPE is majority or wholly owned by a Chinese company called Shanghai Bi Ke Clean Energy Technology Co. Ltd. (commonly called "CECC". Most shares (45%) of CECC are owned by the Chinese Academy of Sciences Holdings Co. Ltd. (CASH), which is a state-owned company and the investment arm of the Chinese Academy of Sciences, a Chinese government agency. The other significant (44%) shareholder in CECC�called Double Green Bridge Hong Kong�appears to be composed of managers of CASH. The Chinese Academy of Sciences controls the methanol proposal and merely "uses the dab of Northwest Innovations Works." The Chinese government has legal or actual control over NWIW.

Having learned that this whole endeavor would be owned and operated by the Chinese government, I find the three security risks listed below of grave concern and urge Ecology to address them in preparing for the FSSEIS.

1. Foreign Control of Infrastructure

The future viability of our three key arterials (rail, interstate and water) could be in question if this refinery is built. This threat to our infrastructure systems has to do with size, location and ownership.

There are seven methanol refineries in the U.S. The largest is on 1,000 acres, and the smallest on 230 acres to provide sufficient buffer should there be a spill or explosion. The proposed Kalama refinery is almost as large as all seven existing methanol refineries COMBINED! Knowing this, the size and location of the NWIW refinery could not be worse.

This proposed world's largest fracked gas-to-methanol refinery would be built on a mere 92 acres, literally adjacent to BNSF rail line, approximately an 1/8 of a mile from I 5 and on and in the Columbia River with no buffer protection of additional acreage! Should there be a worse-case explosion at the refinery, all means of transportation (rail, interstate and water) for commerce, first responders and personal use would be destroyed leaving the northern and southern sections of I 5 and BNSF rail completely cut off at Kalama taking years to replace at an astronomical price.

It is important to remember that this is not a harmless widget factory. This refinery could best be described as a toxic, volatile petrochemical behemoth encompassing the entire 92 acre site.

To understand the potential dangers inherent in a facility like this, I will briefly discuss a few of those dangers.

NWIW assures that the methanol storage tanks are designed to withstand a 9.0 earthquake. Considering these eight 105' x 145' tanks, each holding 9.4 million gallons of volatile methanol, would be located on: soils with a moderate to high risk of liquefying in an earthquake; the same fault line that shut down Trojan; 36 years of dredged spoils (fill); a designated floodplain....defies logic! Fill, floodplain, fault line. A true 'perfect storm' for disaster!

BNSF passenger service speeds past the east end of the refinery at 79 MPH. Two of the massive 9.4 million gallon methanol storage tanks are located at that far NE corner of the site close to the BNSF tracks. Train service numbers approximately 39 trips a day of varying types. The thought of one derailment into those storage tanks is horrifying.

Another area of concern is the proposed 24" fracked gas pipeline needed to service the refinery. This line would run under the BNSF tracks and all six lanes of I 5. Soils are questionable in this area concerning movement putting pipelines at risk for rupture and explosion. I vividly remember witnessing the rupture and explosion in 1997 of the NW Pipeline due east on the Kalama River hillside at Mahaffey. The fireball could be seen for miles and pelting rock and debris showered down a mile away.

Tragically, there could also be numerous threats to our beautiful Columbia River from increased shipping traffic to and from the refinery. 800' - 1,000' Panamax ships (unaccustomed to the Columbia River) carrying 14 million gallons of methanol would make 72 - 144 round trips in the river's rather shallow 43' channel. More unsettling is knowing that a minute spill of only a gallon of methanol into 198,000 gallons of River water would kill all marine life!

2. Foreign Control of a Major Energy Asset

If this refinery is approved, another glaring security risk would be the staggering amount of fracked gas consumed each day�more than all gas powered plants in WA; more than all industry in WA; more than all homes; more than all commercial businesses in WA. At this massive consumption rate, WA residents and industry would be competing with the Chinese government for our own resources! This exploitation by China of our natural resources would create long-term impacts on U.S. energy resources creating a national security risk.

The stark reality for Washingtonians is this... if the Kalama methanol refinery gets built, China will control ALL of the excess fracked gas capacity in the state. Thereby controlling ALL new or existing gas industries future plans to build or expand here in WA. Is this the future we want to see for our state?

3. Foreign Ownership and Entanglements

The unvarnished truth: The government of China wants methanol and they are using our money and our resources to get it!

The Chinese government's quest to control the world's technology and energy natural resources by 2030 was recently highlighted by Attorney General Barr: "The ultimate ambition of China isn't to "trade" with the United States. It's to "raid" the U.S."

This refinery proposal is a prime example of Attorney General Barr's remarks. China's voracious appetite for our vital natural resources would unequaled!

To add insult to injury, are China's numerous brazen schemes to make sure Washington taxpayers and U.S. taxpayers pick up the "tab" for the cost of the entire project.

One of the most blatant and outrageous schemes: NWIW wants U.S. taxpayers to bear the full financial risk�up to $2.1 billion�if the refinery fails! NWIW is asking the U.S. Department of Energy for a loan guarantee. If NWIW goes bankrupt, the federal government (U.S. taxpayers) could be responsible for paying some or all of the $2.1 billion cost of building the methanol refinery.

China's evading financial responsibility for the building costs of the refinery go hand in hand with ensuring that financial responsibility for any accidents or any worse-case explosions at the refinery would be minimized and capped thru Limited Liability Co. designations for NWIW and it's parent company Pan-Pacific Energy Corporation, a Delaware LLC. Just one more way Kalama, Cowlitz County and Washington state will "be left holding the bag" courtesy of China!

It should be noted that according to NWIW, the refinery components would be built in China and assembled here. One more half truth promised to local union workers. So much for "Made in America". With China you get "Assembled in America". And with "Made in China" you get China's specifications and quality (?) controls not ours!

I urge Ecology to be mindful of these three security risk issues that I have previously detailed. I believe that they have been overlooked during the entire five-year EIS process.

I thank you for extending the public comment period and ask you to deny the permit.

No attachments

Comment From: Sam Kern

10/09/20 @ 4:25 PM
Dept of Ecology–

I am writing to ask your department to reject the NWIW application. I called into one of the public hearings and many of the claims made in support of the Kalama facility cited two things: that the methanol would be used in plas...↓

On the first claim, it appears Ecology is already skeptical that the methanol would not be burned for fuel. The list of "Preliminary Report Findings" on the WA Ecology website on the project mentions the likelihood of this happening.

On the second claim, I read the SEIS and was concerned to see that it did not include a mitigation plan for regional pollution. I am unsure all of the pollution can be mitigated – an emissions increase in the area can not be undone. Cancer-causing chemicals and air contaminants can not be negated; localized pollution is very hard to mitigate. It would not suffice for NWIW to buy offsets, because the air pollution would be happening adjacent to our communities, where it poses a health risk. This can not be mitigated, even if NWIW HAD gone so far as to release a plan in their SEIS (and it is a problem that they did not do this, while still relying on their private mitigation plan as a selling point to the public).

Additionally, I am concerned about the water usage from the Columbia River. This does not seem like the kind of project worthy of disrupting ecosystems, or laying the foundation for future pipeline expansion. NWIW is giving every indication that this is an anchor project and would likely necessitate further natural gas pipeline expansions in the state of Washington, as (it is my understanding that) the existing pipelines are operating at near-capacity.

Investing in more dangerous natural gas pipelines is not something I hope our state will do, as the Pacific Northwest region has recently experienced multiple natural gas pipeline explosions. The Kalama refinery will open the door to expansion of infrastructure that will put our communities at risk, ESPECIALLY considering that most of the Pacific Northwest region is preparing for the inevitability of a massive earthquake.

I don't think the SEIS is accurate in positing that extractive fuel sources will increase in demand at the proposed rate. This seems highly speculative – between the time the first SEIS was filed and the second SEIS was submitted, major changes have been made in the global economy that indicate a shift away from extractive fuels. For one thing, massive investing firms like Blackrock and global buyers like Google, Microsoft, and Amazon have announced transitions away from extractive fuels. China itself has announced new energy plans that indicate a desire to move away from polluting fuels. I do agree that we will not likely see plastic production slow any time soon, but considering it's highly suspect that this is what the Kalama refinery will be solely used for, I think that the SEIS relying on old market trends to justify its necessity is suspect.

As a final point, this is not the kind of investment that signals an interest in public health, public safety, or a responsible future for our state. I urge you to deny the Kalama refinery proposal.
No attachments

Comment From: Bryan Smith

10/09/20 @ 4:19 PM
I oppose any new fossil fuel infrastructure because it is contraindicated by a clear majority of climate scientists, ecologists, biogists, economists and the IPCC. Renewable energy is now cheaper than fossil fuels, so the only reason the fossil fuel ...↓
No attachments

Comment From: Cathryn Chudy

10/09/20 @ 4:17 PM
I have submitted a number of comments, as well as testified at the public hearings regarding the Kalama Methanol proposal, and have read many of the comments as submitted online here.

I am opposed to the Kalama Methanol proposal and believe that the S...↓

I am including in this comment the following "Note to Ecology" submitted to you by Kalama resident Linda Horst. Due diligence by Ecology should include not only the analysis of greenhouse gas pollution impacts of this proposal, but also the soundness of the company proposing the refinery. We are relying on your decision-making to protect our precious shoreline and ensure a good faith "do no harm" outcome for Washington. It is impossible to conclude (after reading Linda's analysis) that NWIW LLC is a reliable and trustworthy proponent that will do right by Washington going forward.

_____________________________________________________________________

Note to Ecology:

Admittedly, the following comment listed below does not critique GHG emissions, displacement or mitigation issues. My comment will, however, address the bona fides, or lack thereof, for Northwest Innovation Works to reliably and fully implement during the next 40 years their commitments contained in the DSSEIS: lowering GHG emissions; displacement of other dirty fuels; and 100% mitigation of all in-state direct/indirect GHG emissions.

The saying "All hat, no cattle" comes to mind when I consider the role of Northwest Innovation Works in their high-stakes, paper shell game they are waging with Ecology in this Draft SSEIS process.

While Ecology has invested considerable time and money researching and analyzing the myriad aspects and ramifications of this proposal, alarmingly zero attention has been devoted to the qualifications of the proponent of this climate/life altering refinery!

It is unconscionable that this upstart company that has never built a methanol refinery, never operated a methanol refinery or ever produced a drop of methanol is, in fact, proposing to build, operate and produce methanol in what would be the largest fracked-gas-to-methanol refinery in the world! Too ludicrous to be true? Tragically it appears not to be too ludicrous for every governmental agency in Washington state that has been tasked with reviewing this proposal for the past 6 years!

How did this meritless company get this far?

NORTHWEST INNOVATIONS WORKS LLC:

• No employees — according to WA Secretary of State, NWIW Kalama LLC has no active license with L & I — no covered employees

• No income — since forming their LLC, zero income from methanol sales

• No assets — business office rented not owned

• No credentials — no documentary evidence

• No experience building a methanol refinery

• No experience operating a methanol refinery

• No EPA approval for the ULE technology proposed to decrease GHG emissions

• No methanol refinery has ever used both ULE and ZLD technology together

They say "The devil is in the detail". The preceding "No —" details are red flags I trust Ecology will not ignore.

There are almost as many red-flag comments submitted against this refinery proposal as red-shirted "No Methanol Refinery" opponents! All of us urge you to deny this permit.
_____________________________________________________________________

I add my voice in support of these observations and concerns as raised by Linda Horst in the above comment.

I believe that the only outcome "good for the environment" that serves Washington is to allow our state to move forward with the climate goals that have been initiated by Governor Inslee (who has stated he cannot support this proposal in light of those goals).

We need Ecology to do its due diligence by taking into account the shaky foundation on which NWIW LLC actually rests, a foundation that clearly appears to be cobbled together on quicksand rather than built on solid ground. Quicksand will no doubt swallow up any lip service that has thus far been offered to voluntarily "mitigate" the actual harms to Washington that Ecology clearly outlines in its SSEIS.

We ask you to keep the faith with the vast majority of Washingtonians as well as those throughout our region who have urged you to deny the Shorelines permit and ultimately reject the project.
No attachments

Comment From: Chris Bauer

10/09/20 @ 4:13 PM
The Washington Department of Ecology has set a goal of reducing carbon emissions by 40% by 2035. While I do not believe that goal is ambitious enough to prevent the worst effects of climate change, approving this project will send a message that even...↓

Furthermore, on a recent call, it was stated that this proposal does not seek to mitigate CO2 emissions outside of Washington State. The Department of Ecology should consider the totality of projected emissions, even if most of the emissions enabled by a project would occur outside of Washington. After all, this 2035 goal was undoubtedly set with the aim of mitigating the effects of climate change � it does not matter if emissions occur in the US, or in China. We can no longer disregard the harm of outsourcing our pollution to other parts of the world.

Finally, this new refinery would necessitate an expansion of natural gas pipelines in Washington state � this investment in fossil fuel infrastructure would be a misplacement of priority and have the negative effect of lowering the barrier to entry for new emission-heavy projects in the state. For all of these reasons, I believe Washington should reject this proposal.
No attachments

Comment From: Susan Hildreth

10/09/20 @ 4:10 PM
My comments on the Kalama Manufacturing and Marine Export Facility Second Supplemental EIS are included in the attached file "Kalama Methanol Comments.pdf".
Attachments:

Comment From: Anonymous Anonymous

10/09/20 @ 4:08 PM
Thank you for this opportunity to comment on the proposed Kalama Manufacturing and Marine Export Facility. I am a member of the Green Team at Keystone United Church of Christ. As such, I advocate for upholding Washington's climate action commitmen...↓
Clearly the proposed project's expected emissions of GHGs in the range of 4.6 MMT/CO2/yr to 9.4 MMT CO2/yr would threaten Washington's GHG emissions goals.
Less clear from the SSEIS is the likelihood of the proposed project's displacing more GHG intensive sources of methanol over a 40 year period given the difficulty of predicting such factors as technological developments, Chinese consumer behavior, and global commodity markets.
The SSEIS assumes increasing demand for methanol, failing to consider the likelihood that China will take action to address the climate crisis that would reduce demand for methanol. As analyst David Roberts writing for Vox (9/25/2020) indicates, China is under great pressure to decarbonize: "China has a lot to lose from unmitigated climate change, from catastrophic floods to worsening heat waves and sea level rise [impacting coastal cities like Shanghai by 2050]..."
A report published 11/20/2019 by The Energy Transitions Commission and the Rocky Mountain Institute, entitled "China 2050: A fully developed rich zero-carbon economy," offers a model for China's becoming carbon neutral by midcentury. The model covers decarbonizing across all sectors, most relevantly the chemical sector, including methanol for plastics through greater circularity of plastics and demand reduction. China is already taking steps in this direction with the prospect of reducing demand by 45%.
Also relevant, the model covers decarbonizing transport, including a transition to all electric passenger vehicles, which would eliminate the need for methanol as transportation fuel. Current policies are fostering this transition.
Also unclear from the SSEIS is in what way the potential for the proposed project's possible displacement of other sources of methanol balances or justifies the expected upstream and midstream emissions of the project.
The SSEIS fails to consider the proposed project's large requirement for gas that would almost certainly lead to the expansion of our gas pipeline system, which in turn would result in additional gas-based projects. that would result in more GHG emissions, significantly more in all likelihood.
The mitigation plan is insufficient for not covering emissions from fracking in Canada, shipping, conversion to plastics and use as fuel in China.
I oppose the project for its threat to achieving Washington's climate action commitment.

No attachments

Comment From: Beth Hamilton

10/09/20 @ 4:06 PM
Dear Ecology

A ship just ran aground on the lower Columbia River this week. We have enough traffic on the river as it is. Nothing is forever, things break, miscalculations and human errors happen.
Let China deal deal with this mistake when it happens...↓

It's not right that companies and builders have been jumping through hoops to comply with state energy standards just to have China come and use as much energy in one day as some do a year. What is it all for?

How is China helping the globe with GHG? Oh by throwing plastic in the ocean and moving their chemical plants to another county.

Watch the documentary The China Hustle. Eye opener.

Thanks for your time
Beth

No attachments

Comment From: Mike Ellison

10/09/20 @ 4:05 PM
See File for my comment with better formatting (PDF_.
Kalama Methanol Refinery Comment on the Draft Second Supplemental Environmental Impact Statement
10/9/2020
I am Mike Ellison of Vancouver, WA. I moved to Vancouver when I was 6 weeks old and have liv...↓
Every day I enjoy the beautiful environment and the community that supports me here in Washington. I want those who follow me, including my children, to live as enjoyable a life as I have. Global warming threatens this, so I have a responsibility and a desire to respond. I've been privileged to benefit greatly from the long history of GHG emissions that have brought so much prosperity to the developed world. I also recognize that there are many in the developing world that are missing out on these benefits and are already experiencing the brunt of climate chaos. Their plight also motivates me to speak out.
I'm going to focus on a few of the flaws is see in my reading of the Draft Second Supplemental EIS's analysis.
The urgency to reduce GHS emissions: The IPCC Special Report about the difference between 1.5 and 2C warming
It is very important that the lifecycle global warming potential (GWP) of the project must be addressed by the DSSEIS because all the GHG emissions resulting from this project impact climate on a global scale and because science and our own experiences tell us we are nearing a dangerous level of climate chaos. And, of course, warming on a global scale impacts Washington state. The IPCC Special Report about the difference between 1.5 and 2C warming released in October reinforces the need to limit global warming to 1.5C�at least. This science-based IPCC report tells us that we must achieve GHG emissions reductions of 45% from 2010 levels by 2030 to limit warming to 1.5C . The Draft Second Supplemental EIS must recognize the need for this dramatic reduction in only 10 years. In fact, it does note that we are significantly behind our 2020 goals set by the Department of Ecology. This is not the time to add fossil fuel infrastructure that will lock in at least 4.6 MT CO2e/year emissions for 40 years.
Furthermore, we need to remember the IPCC has a history of successive reports that have had to admit their earlier predictions underestimated the pace at which climate chaos is coming upon us. In fact, the Guardian reported , "Bob Ward, of the Grantham Research Institute on Climate Change, said the [Special Report on 1.5 C warming] was 'incredibly conservative' because it did not mention the likely rise in climate-driven refugees or the danger of tipping points that could push the world on to an irreversible path of extreme warming." Modeling in the DSSEIS needs to consider much more dramatic cuts than 45% by 2035. The modeling in the DSSEIS isn't adequate to protect the well-being of Washingtonians and our neighbors around the world. We must not take chances with our general welfare, our economy, and our life support system.
Speculative Displacement Assumptions in the DSEIS
Probably the most egregious flaw of the DSSEIS is its highly speculative, but very limited assumptions regarding the range of alternate cases for methanol sources to make olefins absent the KMMEF. These assumptions are central to the justification of the project. These are unreasonably speculative because (a) world is awakening to the downsides of plastics, and may decide to stop using so many, a possibility not considered; and (b) the timeline of 40 years can't be predicted with the certainty needed when making such a grave decision.
We must consider that the possibility that some of the methanol will be diverted to transportation fuels. However, transportation must electrify to meet the Paris agreement goals resulting in reduced demands for methanol as a fuel. Again, the competitiveness of the methanol market can't be predicted 40 years into the future.
The urgency of reducing GHG emissions means that we can't risk our future on such an uncertain market analysis. You could say that depending on this part of the DSSEIS analysis is risking our future on an American-made Chinese fortune cookie message. But, in addition, building fossil fuel infrastructure with a 40 year lifetime, locks in a market momentum that is very likely to drive us past GHG emission levels that will be disastrous.
Treatment of methane emissions in determining the GWP of the project
A 2018 case study report on this project by the Stockholm Environmental Institute points to research that the assumption of 1.46% as an unrealistic upper bound for the upstream methane leak rate. It is more likely this is 2 to 4.5 times greater. New reports indicate that leakage rates in British Columbia are underreported by a significant amount.
The assumptions used for the GWP of the upstream methane emissions in the DSSEIS are very important, especially when the near-term GHG emissions reduction required by the IPCC Special Report is considered. As you know, methane emissions exert a much greater radiative forcing than carbon dioxide, but methane breaks down more quickly in the atmosphere. Generally, the GWP of GHG emissions are considered on a 20-year or 100-year basis depending on the question being asked. Because we understand the level of GHG emissions reduction required over the next 10 years , the 20-year GWP is the realistic assumption. The 20-year GWP (AR5) of methane is 84 times that of CO2. The DSSEIS's use of a 100-yr GWP of only 28 is wildly unrealistic.
In 2014 Jessika Trancik and Morgan Edwards of MIT directly addressed this issue and argued that the 100-year GWP value is not only unrealistic, but dangerous. "The problem is that now we're actually closer to reaching and potentially exceeding the commonly cited climate targets," Dr. Trancik says. "If our time frame for stabilizing radiative forcing is 20 or 30 years, we shouldn't use the 100-year GWP for our analysis."
When you add to this the unrealistic leak rate for upstream methane, it is clear the DSSEIS doesn't fully account for the critical near-term GWP of the methane emissions.
Role of the administration's deregulation of methane
Because the current federal administration is seeking to reduce regulation of fugitive methane emissions from gas wells that are likely to become feedstocks of the refinery, it is necessary to redo the modeling of upstream methane emissions to include regulatory reform in the direction of looser emissions controls in the analysis. This is another way the DSSEIS is incomplete and unrealistic.
Conclusion
Because of the unrealistic assumptions in the DSSEIS that I've noted plus the urgent need for near-term dramatic GHG emission reductions, I believe that there are Unavoidable Significant Adverse Impacts of the project. The Department of Ecology should reject this methanol refinery, and deny the Shorelines Permit for the project.
Sincerely,
Mike Ellison, PhD
4303 NE 14th Ave
Vancouver, WA 98663

--------------------------------------------------------------
Intergovernmental Panel on Climate Change, "Global Warming of 1.5 oC," 2018, https://www.ipcc.ch/sr15/.
Jonathan Watts, "We Have 12 Years to Limit Climate Change Catastrophe, Warns UN," The Guardian, October 8, 2018, sec. Environment, https://www.theguardian.com/environment/2018/oct/08/global-warming-must-not-exceed-15c-warns-landmark-un-report.
Watts.
Peter Erickson and Michael Lazarus, "Towards a Climate Test for Industry: Assessing a Gas-Based Methanol Plant," Discussion Brief (Stockholm Environment Institute, February 6, 2018), https://www.sei.org/publications/assessing-gas-methanol-plant/.
Emmaline Atherton et al., "Mobile Measurement of Methane Emissions from Natural Gas Developments in Northeastern British Columbia, Canada," Atmospheric Chemistry and Physics 17, no. 20 (October 19, 2017): 12405�20, https://doi.org/10.5194/acp-17-12405-2017.
Intergovernmental Panel on Climate Change, "Global Warming of 1.5 oC."
Morgan R. Edwards and Jessika E. Trancik, "Climate Impacts of Energy Technologies Depend on Emissions Timing," Nature Climate Change 4, no. 5 (2014): 347�352, https://doi.org/10.1038/NCLIMATE2204.
Nancy W. Stauffer, "Assessing Climate Impacts of Energy Technologies," Main, December 15, 2014, https://energy.mit.edu/news/assessing-climate-impacts-of-energy-technologies/.

Attachments:

Comment From: Mike Reuter

10/09/20 @ 3:43 PM
I am speaking here as an individual and not as the Mayor of Kalama.

This is how fast the NW can have devastating natural gas caused by consumers and businesses not allocating and prioritizing natural gas capacity. The two articles below show how it to...↓

In 2012 Nstar reduced their rates by 34%, and just two years later, in 2014, NSTAR raised their rates by 29%.

Abundant Natural Gas Means Low Prices, Increased Trade Potential by I E R A P R I L 1 9, 2 0 1 2

Natural gas production in the United States is hitting unprecedented highs, storage tanks are filling, and prices are falling to levels not seen in a decade. American consumers are benefiting from the glut while gas producers are looking toward oil to keep profits from plunging for their stockholders. This leap in natural gas production is caused by American ingenuity applying hydraulic fracturing and horizontal drilling technology to natural gas previously locked in shale formations. Hydraulic fracturing uses water, sand and trace amounts of chemicals to break open shale rock and release natural gas and oil deposits that could not be produced economically with conventional drilling methods. Private industry in the U.S. has, literally, drilled our way to lower natural gas prices, and these lower prices have ignited a new flurry of new proposals for the use of abundant, affordable natural gas supplies.

As the price of natural gas has plummeted, consumers have benefited from lower electricity rates and the lower cost of manufacturing, creating thousands of jobs.

In February, Boston-based utility NSTAR announced to its business customers that it will reduce their retail electricity rates this spring by 34 percent, to 5.5 cents a kilowatt-hour down from 8.5 cents. In May, the company expects to announce rate reductions for residential customers.

NStar seeks a 29 percent hike in electric rates.
By Jack Newsham Globe Correspondent, November 7, 2014, 10:49 p.m.

NStar blames the cost of supply, because of an overwhelmed pipeline network, for the price hike.
"Because of the current gas pipeline capacity issues, this supply rate is considerably higher than it has been over the past several years," said Mike Durand, a spokesman for NStar.
NStar's parent company, Northeast Utilities, proposed a major pipeline project in September.

If permitted, this natural gas export methanol terminal would supply Asian markets. Washington State customers will be competing with buyers in Europe, Asia, and other markets currently paying far higher prices. Under this perverse outcome, Washingtonian customers would subsidize billions in pipeline construction costs to facilitate exports that would drive domestic prices substantially.

We would have a natural gas addiction � Increasing our pipeline capacity, and consequently increasing our reliance on natural gas, would only further expose us to market volatility.

I know that the Department of Ecology has no say in natural gas security. However, I also know that this refinery needs an expansion of the pipeline to run it 24 hours a day, 365 days a year. The expansion is part of the study when it comes to the environmental review process. Is there really 500 Dtpd capacity in the pipeline on an average day. What is an average day, and how many of them are there? What about winter months, what kind of capacity is there?

No attachments

Comment From: Katherine Muller

10/09/20 @ 3:36 PM
Washington should reject Northwest Innovation Works' (NWIW) proposal to build and operate the world's largest fracked gas-to-methanol refinery in Kalama. According to NWIW, their mission in pursuing this project is "to produce the world's cleanest me...↓
No attachments

Comment From: Theodora Tsongas

10/09/20 @ 3:34 PM
Please see attached file. Thank you.
Attachments:

Comment From: Bill Adams

10/09/20 @ 3:17 PM
Please do not let this Kalama methanol refinery project go any further. Should you allow it to happen, its voracious appetite for up to 130 million cu. ft. of natural gas a day will simply mean more fracking to satisfy this demand. Fracking forces hi...↓
But that can't happen if we keep building refineries like this one that so heavily depend on a fuel that requires fracking to make its product. This is not in our state's best interest nor the entire planet's for that matter. Please reject it. Thank you, Bill Adams
No attachments

Comment From: MARRENE JENKINS

10/09/20 @ 2:58 PM
Dept. of Ecology,

I hope you are feeling overwhelming grateful for the tremendous response to the SSEIS. I am a resident of Kalama for only 12 years;but this was to be my forever/retirement move after 9 homes in a 40year span. On hearing about this pr...↓

I wasn't going to be alone. There were agencies today to protect us. They came about in the 70s when a very big need to stop and reverse the pollution of cars and industries was identified. Amazing! Departments of Ecology in many states and the EPA were so successful. The work will never end and most of the work will be prevention. So thank you to the many hundreds who joined us here in Cowlitz County. Each letter of opposition conjured up memories of a filled convention/fairgrounds center, a sea of red shirted folks united in opposition.
Thank you to the scientific brains who were able to separate facts from fictitious speculation. You were able to supply evidence of the enormity of this plan from the source to completion.

In the end, the final is that this refinery will contribute 4.6 million tons of GHG emissions yearly IF built. There's no mitigation because there are NO binding contracts with the Chinese Government. The Chinese Government fails to honor contracts, bullies neighboring free territories-Taiwan and Hong Kong. The Chinese Government has both a recent and long standing record of lieing and bullying. Until they reverse this and for decades, our Port of Kalama dealings with them should stay in grain,food,and wood.

In the future,if America needs plastic manufacturing for uses here in the USA, it should be done here, close to the source of product. We have high standards in the US and manufacturing plants have no place in densely populated locations along the Columbia River

Future generations will have to be responsible for defining how to accomplish renewable energy and what products will be necessary to accomplish this and be sure what America needs is made in America..Thanks to the leadership of CRK,Sierra Club, Earth Justice, etc., the work to protect our corner of the world and planet as a whole successfully continues.

I pray daily truth will prevail. It's been a long 41/2 years. May it finally be done and buried .
No attachments

Comment From: James Plunkett

10/09/20 @ 2:54 PM
Director Watson:
We have to take every opportunity we have to stop GHG emissions. The plant's incidental methane leaks in the upstream supply are too great. Methane is difficult to capture and seal in pipes and pumps and valves. The fossil fuel indus...↓

thank you

No attachments

Comment From: Anonymous Anonymous

10/09/20 @ 2:41 PM
Sacrificing my local environment quality is not worth the improvement of global environment quality. It also seems redundant for a foreign-owned company to operate a plant outside their country, just to have the product shipped back to them for their...↓
No attachments

Comment From: Jessica Taylor

10/09/20 @ 2:35 PM
Dear WA Department of Ecology,

As a person of faith, I believe we are called to care for both the well-being of communities and the environment.

Inherent in this moral imperative is investing in a livable future that is safe for all to thrive.

Building ...↓

The second Supplemental Environmental Impact Statement for the Kalama methanol refinery clearly shows that this project is dirty, dangerous, and unwise. If built, our state will be locked into decades of additional climate pollution, even though we know it is past time to pursue a truly low-carbon future. Speculating that this project may displace other fossil fuels is not adequate justification for the known pollution that will harm our communities and climate.

Northwest Innovation Works has demonstrated that they are deceptive and will seek profit over people's wellbeing. They cannot be trusted to mitigate the impacts of this fracked gas refinery. The fact that the project has needed three reviews, with outspoken community opposition during each, shows that there is something wrong with it at its core. As Governor Inslee stated, we cannot support such fracked gas projects in good conscience.

You have a moral responsibility to protect public health and reduce our region's climate pollution. Please do what is right and deny this project. Thank you.

Sincerely,
Jessica Taylor
2114 12th Ave E Seattle, WA 98102-4137
Jltaylorsp@yahoo.com
No attachments

Comment From: Terry Teigen

10/09/20 @ 2:33 PM
Dear WA Department of Ecology,

As a person of faith, I believe we are called to care for both the well-being of communities and the environment.

Having spent almost all of my 66 years near and on the waters of this region, I have seen the measurable, i...↓
Fortunately, our state can be part of the solution. My grandchildren and yours will thank us. This is what we are called to do as thinking and caring people living in this critical moment. So much depends on US and our actions.
Please attend to the statement below.

Building the world's largest fracked gas-to-methanol plant in Washington does not align with my personal values of stewardship and justice, nor does it support our state's commitment to reducing climate pollution. Please reject Northwest Innovation Work's proposed methanol refinery in Kalama and deny its Shorelines Permit.

The second Supplemental Environmental Impact Statement for the Kalama methanol refinery clearly shows that this project is dirty, dangerous, and unwise. If built, our state will be locked into decades of additional climate pollution, even though we know it is past time to pursue a truly low-carbon future. Speculating that this project may displace other fossil fuels is not adequate justification for the known pollution that will harm our communities and climate.

Northwest Innovation Works has demonstrated that they are deceptive and will seek profit over people's wellbeing. They cannot be trusted to mitigate the impacts of this fracked gas refinery. The fact that the project has needed three reviews, with outspoken community opposition during each, shows that there is something wrong with it at its core. As Governor Inslee stated, we cannot support such fracked gas projects in good conscience.

You have a moral responsibility to protect public health and reduce our region's climate pollution. Please do what is right and deny this project. Thank you.

Sincerely,
Rev. Terry Teigen
5029 36th Ave SW Seattle, WA 98126-2805
terrypteigen@gmail.com
No attachments

Comment From: Cambria Keely

10/09/20 @ 2:31 PM
Over my four-and-a-half years spent researching the proposed Kalama methanol refinery, one of the statistics I felt has been widely ignored is the deoxygenation of water by methanol. One gallon of methanol can deplete 198,000 gallons of water of oxyg...↓

Section 3.5.1.3 of the DSSEIS discusses the marine transport (MT) vessels. The low and medium emissions estimates are based upon the concept of 100,000 tankers annually, contributing to the emissions of 197,344 CO2e per year. If 100,000 tankers spill a mere tablespoon of methanol per fill, over 77-million gallons of water would be deoxygenated. Is contributing to forty years of polluting our ecosystem really the way to respect our River, our town, and our future? I find it truly disturbing that this statistic was discussed nowhere in the DSSEIS.

No attachments

Comment From: Cambria Keely

10/09/20 @ 2:29 PM
Section 3.5.2.2 of the DSSEIS discusses China's methanol usage rate over the past couple of decades. It states that China used around 60 million metric tons of methanol in 2018, 6 times that of a decade prior. With the use of methanol growing at this...↓
No attachments

Comment From: Cambria Keely

10/09/20 @ 2:27 PM
I recently took a job that involves the analysis of a decade's worth of Reuters articles. I noticed that one recurring theme of every economic recession is that oil prices drop extremely low, sometimes into the negative, leaving investors with thousa...↓

Section 3.5.2.5 of the DSSEIS discusses the price of methanol, which made me realize that methanol could very likely follow the same trends as oil if you permit this facility to ramp up methanol production. When the price of methanol inevitably eventually drops, where will we store all the overstock? Will it simply be sitting in Kalama for months, years, decades, waiting for an earthquake or a fire to cause a disaster?

There are far too many unanswered questions and unconsidered situations that go along with this facility. After a year of the world proving to us that anything could happen at any time, the last thing Kalama needs is for this project to introduce so much uncertainty and risk. Please say NO to the KMMEF.

No attachments

Comment From: Michelle Johnson

10/09/20 @ 2:18 PM
I strongly oppose the construction of the world's largest fracked gas-to-methanol refinery in Kalama or anywhere in Washington State. We should not allow KMMEF or any company to come in and permanently destroy our environment. Ecology needs to re-e...↓
No attachments

Comment From: Diana Gordon

10/09/20 @ 2:12 PM
NWIW will be never be able to mitigate the vast quantities of greenhouse gases that the Kalama Methanol Refinery will produce.

Mitigating only the GHG's produced in our state is simply not good enough, anyway. If they are planning to mitigate their e...↓

Why should anyone suffer from the effects of climate change that they have contributed to? What on earth do they have in mind? - maybe building a fire brake around some drought-stricken community so they won't be swallowed in an enormous approaching climate fire?

They are proposing a voluntary program that they will develop as they go along. We have considerable evidence that shows this particular company has not been 100% truthful regarding how they are planning to use this methanol. Using the methanol for vehicle fuel instead of plastic manufacture will produce more GHG's. Will they remember to add a little more mitigation on for that? Why should we trust them to maintain a VOLUNTARY 40-year commitment?

Greenhouse gases are a global problem. They are already driving climate change around the world. Witnessing the fires, hurricanes, floods, winds, drought, and so on caused by climate change does not whet my appetite for some window-dressing type half-measures for 'mitigation'.

Mitigation is hard, very hard, and we are going to have enough work before us to curb our GHG emissions and slowly turn the climate ship onto a more sustainable course. It is dismaying that forests are burning instead of sequestering carbon. It is dismaying that the ocean has already absorbed so much carbon from the burning of fossil fuels that it is not the reliable carbon sink it once was, reliably absorbing about one-third of our CO2.

I feel that we should not pin our hopes for an improving climate future on folks like NWIW. The few jobs they are promising cannot balance the harm that would be caused by this plant. The climate goals for Washington State are to reduce GHG emissions 45% below 1990 levels by 2030, and 95% below 1990 levels by 2050.

We can do it. We can meet those goals. Let's go for it and start by denying the Shorelines Permit for this plant.

No attachments

Comment From: faye allen

10/09/20 @ 2:08 PM
No to the kalama methanol refinery. This plant would require massive amounts water to operate and spew out wastewater and heavy metals filling the air with toxic pollution.
No attachments

Comment From: Oregon Physicians for Social R... (Damon Motz-Storey)

10/09/20 @ 2:04 PM
Please see the attached documents for Oregon Physicians for Social Responsibility comments on the SSEIS for Kalama Methanol.
Attachments:
Download
Download
Download

Comment From: del hamilton

10/09/20 @ 1:50 PM
No to methanol refinery. This plant would open the floodgates for fracked gas refining in the PNW, polluting our air and water.
No attachments

Comment From: Mark Keely

10/09/20 @ 1:50 PM
Referenced in the DSSEIS: 3.3.1.1 Paris Agreement, 3.3.2.1 Federal Clean Air Act, 3.3.3.1 Limiting GHG Emissions (RCW 70.235), 3.3.3.2 Washington Clean Air Act (RCW 70.94), 3.3.3.3 GHG Emissions � Baseload Electric Generation Performance Standards (R...↓

NWIW has not shown any just adherence to these standards or any clear mitigation for the harm and pollution through the operations of this petrochemical refinery. In fact mitigation of 4.6 million metric tons of CO2e is IMPOSSIBLE!

Ecology WA -- your mission statement states, "Ecology is Washington's environmental protection agency. Our mission is to protect, preserve, and enhance Washington's land, air, and water for current and future generations. Our innovative partnerships support environmental work throughout the state." Please abide by it! Adding new fossil fuel infrastructure, obligating us to 40 years of fossil gas consumption, and adding 4.6 MMT of CO2e to our already overburdened atmosphere for even 10 years is a climate disaster from which we cannot overcome. Do your job. DENY the shorelines permits.

No attachments

Comment From: Mark Keely

10/09/20 @ 1:42 PM
The Port of Kalama wants to marry up to the China government-backed Northwest Innovation Works, a limited liability company (whereby the owners are not personally liable for the company's debts or liabilities). Why, if they are so sure of themselves?...↓

The Port of Kalama applied to the federal government for 11.5 million dollars for a dock & road for the refinery. The Port of Kalama applied to Washington State for another 11.5 million dollars which is "double-dipping" for the same cause and it's against the law. Do they know what they're doing? The Port of Kalama asked for a federal loan for 15 million dollars to build a well for NWIW that would take over 5 million gallons of water a day from a freshwater aquifer next to the Columbia River. NWIW lobbied for state tax loopholes valued at 143 million dollars. NWIW wants the US taxpayers to bear the full financial burden of 2.1 billion dollars if the methanol refinery fails. NWIW wants to use Washington public employees retirement funds to build the methanol refinery.

That's 2.681 billion dollars total for taxpayers to be on the hook.

This is U.S. taxpayers cash and the Cash Always Stays Here. Our tax monies are ours for our own improvements on air, water, land, and the health of all the people. Taxes should certainly not be spent to emit 4.6 million metric tons of CO2e per year for 40 years.

The DSSEIS displacement theory is based on pure speculation using cherry-picked data. All for a shell company that wants to exploit our natural resources and garner profits for a foreign country. DENY the permits. No petrochemical company in Kalama!

No attachments

Comment From: Robert Erwin

10/09/20 @ 1:17 PM
Attachments:

Comment From: Julia Mottet

10/09/20 @ 1:11 PM
Comment written on 9/23/2020

I grew up, work and live in Cowlitz County, WA.

We have all been affected by the wildfires on the West Coast this year. We have seen the footage of the golden gate bridge obscured by smoke with a blood red sky. Portland h...↓

According to Wikipedia, the 2020 Atlantic hurricane season, with 23 named storms so far, it is the second most active Atlantic hurricane season on record, only behind only the 2005 Atlantic hurricane season, (of Hurricane Katrina fame). Tropical Storm Cristobal and 19 later systems have broken the record for the earliest formation by storm number. In addition, this season is the first to see seven named tropical cyclones make landfall in the continental United States before September. September is not even over, and we've just experienced the most active September on record. With hurricane season not officially over until November 30, we may break the record yet for the most active hurricane season ever.

Last Friday, 9/18/2020, the rain came down so hard and fast that I had to use sandbags to keep the water away from my garage. I live half way up Columbia Heights Road. I am living in a house a block away from where I grew up. I've been here since the 1970s; my grandparents moved here in 1940. We have NEVER had to use sandbags in our lives up here on the hill. I only had the sandbags around to secure a portable basketball hoop for my children.

So between the pandemic, hurricanes, flash flooding, and a smoke-filled orange sky obscuring the sun, it feels like end times. Our face masks, bought for the pandemic, are doing double-duty due to the smoke. I do not know how to comfort my 14-year-old and 9-year-old daughters. I would like to be able to tell them that things will be okay, that people will realize what is happening and make big changes to prevent the destruction of our planet. But I cannot tell them that in good conscience. Global warming is happening; it's affecting our weather, which in turn affects our fire and hurricane seasons, and no amount of hand wringing, shoulder shrugging, head shaking, or hoping things will improve on their own is going to make it go away.

The proponents of the methanol refinery would have you believe that the refinery would decrease the amount of methanol derived from coal-based methods, thus creating a net reduction of greenhouse gases being produced. However, the Chinese have made NO written promises to decrease their coal-based activities if the Kalama methanol refinery were to be built; and even if they did make a written promise, it would be absolutely IMPOSSIBLE for us to enforce. Most certainly, they will simply add the methanol to all their other fuel stocks and coal will continue to be burned at the same rate in China. 'Displacement' is wishful thinking at best and false logic and deceptive propaganda at worst.

For years, NWIW claimed that the methanol would solely be used to produce feedstock for olefin production. This lie was told to make their numbers look for better. Well, there are less environmentally-destructive methods of producing feedstock than fracking natural gas, piping it over many hundreds of miles, refining it into methanol, and then shipping it half a world a way; therefore the comparison of fracked-gas-to-methanol vs. coal-to-methanol was always a sham comparison.

Now they finally admit that some of the methanol could be burned as fuel in China or elsewhere. Well no sh**, Sherlock! Methanol is a commodity and once it is manufactured and sold, the seller has no control over how or for what it is used. We should assume 100% could end up being burned as fuel, since we have no control of it once it leaves our shores.

The question is whether this proposed project is a net gain or net loss regarding greenhouse gas emissions... i.e. does it meet the current laws and standards that we have on the books to safeguard ourselves from planetary destruction?

When you consider all upstream emissions of this fracked gas project and how the methanol may end up being used, it is every bit as bad as coal, the very source NWIW claims to be replacing. This refinery would be a very significant contributor to greenhouse gas emissions. We cannot 'mitigate' our way out of the damage it will do to our planet. The damage would be immediate and ongoing; any so-called mitigation, such as planting trees that take decades to grow, would be too little, too late.

Taking into account ALL upstream emissions, the fact that the methanol may be burned as fuel, and no decrease in China's use of coal-derived methanol due to the aforementioned reasons of no-promise/no enforcement, this becomes a very bad project indeed.

I'm also very concerned about the additional tanker traffic on the Columbia River and what that will do to our salmon and other native fish.

Lastly, I think this refinery is an explosion hazard and too near families with children. All we need is a big earthquake and any safeguards put in place to prevent the methanol from coming in contact with oxygen will be breached. My 14-year-old daughter informs me that we are more than 50 years overdue for a big Cascadia subduction zone earthquake. Apparently we have become forgetful and complacent sometime during the last 300 years since the last one. We cannot afford to build a refinery on hope, as in "We hope the Big One doesn't hit during the lifespan of this refinery" or, "We hope the Chinese will burn less coal like they promised." As the framed wall poster that hung in my high school guidance counselor's office used to say, "Hope is not a form of birth control."

Julia Mottet
Longview, WA
9/23/2020

No attachments

Comment From: Orca Network (Cindy Hansen)

10/09/20 @ 12:59 PM
Attached please find Orca Network's comments on the Kalama Manufacturing and Marine Export Facility.
Attachments:

Comment From: Sally Keely

10/09/20 @ 12:52 PM
Why does the DSSEIS contain outdated stats and cherry-picked outlier rates?

The DSSEIS uses GWP values from IPCC AR-4. Why not the more recent AR-5 values? The more recent assessment with more accurate current data has been available for years. Doing ...↓

The DSSEIS uses a 100-year GWP for methane even though (1) the project is expected to be in operation for 40 years, and (2) the IPCC and other scientists worldwide have proven we have just ten years to dramatically reduce GHG emissions to avoid irreversible climate catastrophe. Over the next 20 years methane has a GWP 86 times that of coal and would make the 4.6 MMT CO2e that KMMEF is shown to emit far, far worse.

The DSSEIS uses a 0.97% methane leakage rate from pipelines. Why cherry pick such a low outlier rate when more accurate rates of 2-3% have been proven again and again? Doing so makes the 4.6 MMT CO2e that KMMEF is shown to emit far, far worse.

Don't permit our climate emergency to become far, far worse. DENY the shorelines permits!

No attachments

Comment From: Don Steinke

10/09/20 @ 12:35 PM
The law requires you to consult with the tribes.
More than that, we should begin to right centuries of wrongs.
The Cowlitz and Chinook Tribes occupied this area.
The Cowlitz and Chinook had to fight for Federal recognition for years. The Cowlitz were s...↓
The Cowlitz oppose the methanol plant.
Let's not screw them one more time.

No attachments

Comment From: Robert Briggs

10/09/20 @ 12:30 PM
Attachments:

Comment From: Sally Keely

10/09/20 @ 12:26 PM
I've been working to stop the methanol refinery for almost 5 years. I've read EVERY word of every EIS, related document, and public comment. There are only 2 reasons ever given to build this monstrosity: the "displacement" theory and jobs, jobs, jobs...↓

(1) The displacement theory in the DSSIES is completely bogus, and everyone knows it. There is NO guarantee China is going to stop burning coal to make methanol. And if NWIW, the Port of Kalama, and Cowlitz County legislators cared one inkling about coal emissions they would have been against Millennium Coal terminal in Longview but instead supported it 100%. The entire displacement theory is completely speculative and should be disregarded.

(2) Ecology's "displacement" argument in the DSSEIS assumes China is never going to work toward a better climate future, so why should Washington. SO INFURIATING! The people of Washington, the Governor of Washington, and I had (mistakenly?) thought the Dept. of Ecology in Washington all "got it" � that we were going to work together toward a clean green future with massive REDUCTIONS in GHG emissions as we QUICKLY transition to sustainable carbon free energies. But the DSSEIS assumes we carry on the "status quo" of fossil fuel use for another 40 years. YIKES! Even doing so for another 10 means "game over" for humanity per the IPCC and other well documented scientific reports. Ecology � you can't really believe spewing 4.6 million metric tons of CO2e every year for the next 40 years can be "displaced" or "mitigated" can you? Come on!

(3) Jobs. Hmph. First off NWIW is lying. The people of Cowlitz County aren't getting living wage jobs � not temporarily in construction (the facility is modular, built in China, assembled here), not permanent (Kalama has not a single Mandarin fluent methanol engineer). NWIW already applied for H1B Visas to bring workers over from China. The rest would come from the gulf coast. And even if we were to get 200 permanent jobs and 1000 temporary, what use is a job when you cannot breathe the air? Or your family member is dying of cancer from 59 toxic pollutants spewed into the air (cite: SEPA 2016)

DENY the shorelines permit and quickly so we can get on with the business of finding a sustainable business to build on the Port's vacant 92 acres. Enough is enough!

No attachments

Comment From: Don Steinke

10/09/20 @ 12:26 PM
I don't know if you have the same authority as EFSEC, but EFSEC can add provisions to a permit.
If you approve the permit:
• require that NWIW be fully insured for a worst-case scenario
• require that NWIW pay for independent monitoring of a...↓
• require that NWIW pay for pipeline monitoring and repair
• require that NWIW build to withstand a worst-case seismic event

No attachments

Comment From: Mark Uhart

10/09/20 @ 12:15 PM
Attachments:

Comment From: Shari Bush

10/09/20 @ 12:11 PM
Dear Director Watson and Department of Ecology,

Please do not permit the world's largest fracked gas-to-methanol refinery to harm Kalama, the Columbia River, and the global climate.

Washington should reject Northwest Innovation Works' (NWIW) proposal t...↓

For the community of Kalama and for our climate, the risk is simply too big. Please keep our communities safe, and keep Washington on track to meet our goals for reducing climate pollution. I am counting on you to do the right thing and stop this dirty, dangerous fossil fuel export project.

Thank you for your time,
Shari Bush
No attachments

Comment From: Desiree Hellegers

10/09/20 @ 12:02 PM
Attachments:

Comment From: Barbara Howe

10/09/20 @ 11:41 AM
While the claim is the emissions of the world will be reduced, I am not willing to increase the toxic output in the area I live to achieve that. I am against this plant being built and operated in my back yard.
No attachments

Comment From: Den Mark Wichar

10/09/20 @ 11:28 AM
Projects such as proposed by NWIW in Kalama amaze me by how proponents feel that they have the right to affect everyone in the world by their very localized decisions. If environmental affects of the proposed facility were to remain solely within Co...↓
No attachments

Comment From: Mike Reuter

10/09/20 @ 11:07 AM
I am speaking here as an individual and not as the Mayor of Kalama.

I asked David Taylor if I could send his letters of concern to the Department of Ecology to help show that thousands of workers and businesses that depend on this one natural gas pipe...↓

Opinion: Methanol plant isn't all it's cracked up to be
David Taylor Feb 8, 2019

I am opposed to the construction of the Kalama methanol plant on the basis of its impact on the Northwest's supply of natural gas and how it would impact the Northwest economy.

Energy is one of the keystones of a vibrant and growing economy. This project would have a significant negative impact on long-term growth and stability of the economy. The amount of gas to supply the operation of this plant is equivalent to the send-out of any of the four natural gas local distribution companies (LDC) serving Western Washington and the Willamette Valley.

The plant would consume 320 million therms of natural gas daily from the existing transmission line from the wells in Canada via a Canadian pipeline to the U.S. border and by the Williams pipeline through their transmission line to the local distribution companies in Oregon and Washington. A residential equivalent for heating is approximately one therm an hour.

Consider also all of the businesses and industries using gas. Through peak heating periods there is not enough capacity in the existing transmission lines to serve all of LDC's needs, for this reason they use peak shaving storage such as LNG or depleted natural gas wells that are refilled each summer to augment the pipeline supply. Flow in the line is relatively steady throughout the year because of this ability to replenish storage supplies closer to home.

Job creation has been a point that proponents of this plant have used. The Kalama plant would have an employment base of just over 100 employees in operation. More during construction, but that is short when compared with the operating life of this plant. Consider also that the plant will be of Chinese design and similar to the 11 other plants they have built around the Pacific Rim. While the civil works for this plant will be built here on site, the reforming equipment will be designed and built in China and barged to the Kalama site. Thus not all of the 2 billion dollars this plant is supposed to cost will be spent here. If built in China the labor rates are substantially lower. The plant will also have to meet Washington requirements of the heat and pressure equipment.

One of the biggest problems I see is the increased demand on the pipeline capacity all the way to the source. That means new pipelines and compressor station facilities will be required. Those costs will surely be passed on to us in the forms of increased transportation rates. Secondly, is the growth and development of new industry in the face of the possible constraints on the pipeline imposed by this plant? Industry will not develop or expand with an unsure energy supply, either at the well head or in transmission. Industry growth is what stimulates residential and commercial development. Problems in energy supply will chase the development elsewhere. Note here also that this plant, besides producing a paltry 100 jobs, does not contribute tax revenues to Washington. The gas is purchased in Canada and owned by the Chinese when it crosses the border and as an export product it is not subject to a sales tax. Furthermore, Cowlitz County is proposing significant property tax reductions for the plant. In effect we will be giving the Chinese a free gift. In the meantime, we will reduce our long term supply at the wellhead by about one third.

I would like to see an independent study on the economic impact of this plant on the entirety of the Northwest economy. My expectation is that the study will show that negative impacts of this plant far exceed its benefits.

About the author
David Taylor moved to Ridgefield in 2005 and presently serves on the Ridgefield City Council. Taylor has 45 years of natural gas engineering experience.
No attachments

Comment From: Anne Bennett

10/09/20 @ 10:39 AM
I writing to register my opposition to this project. As difficult as it is to turn away jobs, particularly now, I believe that this project should be rejected for these reasons.

Whether one believes climate change is human caused or not we should do a...↓

In addition, fracked natural gas produces methane is indicated as GHG 86 times more potent and warming to our atmosphere than CO2. We should invest in projects that move us away from fossil fuels not ones that continue our reliance on them.

To add injury to insult we will use our resources for the manufacture of plastics which we will then buy back. Our oceans are glutted with plastics. Our world would be better served by investments in innovations/manufacturing of products to replace plastic (corn based products?).

Last- this venture will be owned and operated by the Chinese government. I understand the Chinese government owned Chinese Academy of Science Holdings is seeking a $2.1 billion of tax payer money to build the Kalama Refinery. This is unacceptable. In my opinion, this project is shortsighted. It lacks the vision and resolve to embrace strategies that protect the environment. Our resources and tax incentives should be used for this purpose and for US owned or majority owned investments -not in a manner that benefits China over our own interests.

Respectfully submitted,
Anne Bennett
No attachments

Comment From: Mike Reuter

10/09/20 @ 10:18 AM
I am speaking here as an individual and not as the Mayor of Kalama.

This enclosed letter is from a natural gas engineer that echoes my concerns about the gas supply infrastructure and how the only way that this refinery will be able to operate if ther...↓

Natural gas engineer says 'no' to Kalama methanol plant

By David Taylor Feb 14, 2017

I would like to start off by stating that I am opposed to the construction and operation of a Chinese funded methane to methanol plant in the Port of Kalama.

One thing that I have not seen addressed is the effect this plant will have on the long term economy of the Pacific Northwest — British Columbia, Washington and Oregon. The load being proposed in this plan appears to be 3.2 million therms of gas daily. To put that quantity in perspective, that amounts to slightly more than 50 percent of the most recent cold weather peak daily send out of the gas company serving the area from North Clark County to Roseburg, Oregon. The proposed plant would require that amount on a daily basis, 365 days a year, not just in cold weather periods

The issue that I think needs to be addressed is system capacity of the pipeline and the effect of this plant's load in relation to the existing system. In order to carry this added load to the residential customers for heating, industrial loads are cut back by contractual agreements. On a day-by-day basis the line runs at near capacity. The size of the load proposed would be a firm load and not allow curtailments based on the continuous process.

In order to serve the load adequately, it would be necessary to increase the capacity of the line. That would mean the construction of paralleling pipelines in certain areas and the addition of compressor stations to move the gas south to Kelso from the source in Northern British Columbia.

Not having access to the engineering data on the pipelines, I can only surmise that such a capacity upgrade may require an investment as much as the cost of the plant; at least several hundred miles of upgrades and several hundred million dollars and up.

Who will pay for those upgrades? Us the consumers. Williams' fee for transporting gas is based on their investment in the pipeline that they have to pay back to their lenders and an operating fee plus some profit. That fee is spread over all the users of the system. The methanol plant will pay its pro rata share based on the quantity transported and we as gas consumers in our homes will pay our share based on the new higher cost of operation.

The second reason that I do not want this plant built is that it will consume Northwest gas and send it to China to fuel their industry. In the ground, natural gas is a fixed quantity. Granted the fields are large and the quantities are large, but they are still finite. No additional gas is being added to those wells. The issue here is just how long will that supply last? Twenty years, 40 years? Who knows?

A look at the pipeline supply routes for gas to the Northwest are very sparse compared with the rest of the country. Our region has two and maybe three sources. Canada, in Northern British Columbia, and the Four Corners and Wyoming area. Fully 70 percent of the Oregon and Southwest Washington gas is Canadian sourced. Adding a plant with a load the size of a major city will have a definite impact on the life of the field. For me, the British Columbia gas is NW gas and should remain as NW gas. It should not go to China at our future expense.

For me, the British Columbia gas is Northwest gas and should remain as Northwest gas. It should not go to China at our future expense. I think not.

Editor's note: David Taylor is a natural gas engineer and has been involved in the location, design, construction and operation of a very large Natural Gas distribution system serving the Clark County, Portland Metropolitan, and Willamette Valley for over thirty years of his working career. He has forty-five years of Natural Gas Engineering.

No attachments

Comment From: Stockholm Environment Institut... (Peter Erickson)

10/09/20 @ 9:52 AM
Attachments:

Comment From: Mark Canright

10/09/20 @ 9:48 AM
Thank you for your work to protect Washingtons environment and acknowledgement that previous environmental analysis of Northwest Innovation Works (NWIW) Methanol refinery proposal in Kalama, Washington have been inaccurate and inadequate.

This new Dra...↓

Despite these marginal improvements, the evaluation of potential mitigation and displacement contained in this analysis is misleading and concerning in its reliance on speculative and unenforceable assumptions. One can simply look to the impacts of this pandemic to see evidence of incredible uncertainty and volatility in energy market dynamics. It is dangerous to presume this analysis can accurately predict global fuel markets, technology developments, consumer behavior, or regulations for the coming four decades. Furthermore, the SEIS provides too little detail on the actual mitigation that would be accomplished within the voluntary mitigation framework, nor does this mitigation address the full impacts of NWIWs emissions that will occur overseas. The mitigation framework is too vague for Ecology to conclude that this projects impacts will be mitigated, and the urgency of climate change demands that mitigation should be the last option (after all other impacts are reduced) in order to address unavoidable impacts, not simply to maintain the status quo as we continue to build out the fossil fuel industry.

Even with all of its flaws, this analysis confirms that NWIWs proposed facility would become one of the greatest sources of climate pollution in Washington. It is simply unacceptable for Washington to build an unequivocally and enormously polluting facility based on speculative analysis and a faint hope of theoretical emission reductions. Ecology should dismiss the speculative basis that this project could displace even more polluting facilities, and instead should base its permitting decision on what is reasonably foreseeable and indeed, assured, about this project--that it would cause millions of tons of greenhouse gas pollution each year, for 40 years, and is profoundly inconsistent with achieving Washingtons climate goals.

The evidence in this draft SEIS demonstrates that Washington should deny NWIWs proposal to build and operate this dangerous methanol refinery in Kalama. We cannot keep building fossil fuel export infrastructure and expect to address the dangers of climate change.

Please keep our communities safe and keep Washington on track to meet our goals for reducing climate pollution.
No attachments

Comment From: Mark Uhart

10/09/20 @ 9:31 AM
Attachments:

Comment From: Laura Bauer

10/09/20 @ 9:26 AM
I am submitting the attached comments addressing just one of my many concerns with NWIW's proposed methanol plant in Kalama, WA.
Attachments:

Comment From: Lets Build This WA!

10/09/20 @ 9:16 AM
At the beginning of the public comment period, Northwest Innovation Works created a website -- LetsBuildThisWA.com -- to allow supporters of the Kalama methanol facility to sign a letter that would be submitted on their behalf to Director Watson and ...↓

Below (and attached) is the letter that 524 individuals signed. We are submitting this not as one individual comment, but as 524 separate comments to illustrate the extraordinary support this project holds in many the communities across this state and beyond.

----------------------------------------------

Director Watson,

The Dept. of Ecology's draft report on NWIW's proposed methanol facility in Kalama answers all of the questions it was directed to address in a thorough and comprehensive manner. It should be finalized without further change or delay and the permits for this project should be approved.

With this project, we can create jobs in America, where we pay real family-wage salaries and benefits and build things to extremely high and exacting environmental and safety standards by the most skilled workforce in the world.

There's never been a greater need in my lifetime for jobs, especially in rural areas like Cowlitz County, where the economic impact of this project would also provide $30-40 million in tax revenue to local and state governments.

Finally, the science definitively shows that this project benefits the global environment. And the comprehensive mitigation plan ensures NWIW will do the right thing on a statewide basis, making Washington a leader in how to build a sustainable economy.

I urge you to move quickly to finalize this report and approve the permits needed for construction.

Attachments:
Download
Download

Comment From: Ronald Hawk

10/09/20 @ 8:36 AM
The SEIS shows that pollution caused by the Kalama methanol facility would be equivalent to 4.6 million tons of carbon dioxide pollution each year. That's staggering. It means that this one project would be equal to around 5 percent of the state's to...↓
So where are the alleged climate benefits coming from? In a word, speculation.
The project backers are making claims teetering on the flimsy premise: that if Washington fails to supply vast quantities of gas-derived petrochemicals to China then Chinese manufacturers will do something even worse. (Namely, that China will make just as much olefin material, but do it with even-dirtier coal.) If that sounds like tortured logic, it's because it is. It is essentially saying that scientific alarms be damned: we should double-down on climate pollution over the coming decades in the hopes that someone else won't triple-down on it. That's a morally reckless approach to the climate.
Also, on the economics front the SEIS fails to consider the lower price competition that will result from the new very large Russian methanol plant being planned at the Baltic port of Vysotsk.
Clearly, no permits should be issued for the proposed Kalama Methanol plant.

No attachments

Comment From: Sally Keely

10/09/20 @ 8:31 AM
I do not understand how the Department of Ecology can be so misled.

Northwest Innovation Works (https://nomethanol360.com/images/graphic_who-ownsNWIW.gif) is a shell company, a company on paper only, with no current employees, no active Washington Sta...↓

Ecology – you are being sold a bill of goods, don't fall for it!

President Trump wrote in an Executive Order on August 6th, 2020, "... the People's Republic of China (China) continues to threaten the national security, foreign policy, and economy of the United States."

Vice President Pence stated in a debate with Senator Kamala Harris on October 7th, 2020, the Chinese government "did not play straight with the American people."

The Netflix documentary _The American Factory_ describes how a similar Chinese communist party owned company took advantage of a small rural town, not unlike Kalama, and its people, leaving workers high and dry with low wages, no health care, no sick pay, no workers rights that we have come to expect here in the United States.

The same executives including NWIW's Vee Godley tried to start a manufacturing plant, similar to the current proposed methanol refinery in Kalama, in Pocatello, Idaho, leaving it in shambles in 2013 (https://www.nytimes.com/2013/11/06/us/idaho-town-struggles-after-pinning-hopes-on-failed-factory.html).

Do we really want the Chinese communist government having computer-driven control of 72 million gallons of volatile methanol stored on dredged soil at moderate-to-high liquefication risk? That is a huge BOMB just a couple of miles from 3 schools, a day care center, and a retirement village that the China could set off at a moment's notice if aggravated by our government and their trade wars. This proposal is a gigantic NATIONAL SECURITY RISK. Don't let the wool be pulled over your head! Save our county. Save our state. DENY the shorelines permits.

No attachments

Comment From: Northwest Innovation Works (Kent Caputo)

10/09/20 @ 8:23 AM
Attachments:

Comment From: Angus Duncan Duncan

10/09/20 @ 8:17 AM
Please see my comment letter, attached.
Attachments:

Comment From: Anne Kroeker

10/09/20 @ 8:02 AM
October 9, 2020
Dear Department of Ecology,
Thank you for drafting an SEIS focused on a full analysis of the GHG emissions, upstream to downstream, for the proposed Kalama methanol facility and for accepting public comments.
Climate change is not only r...↓
Humans are not the only creatures to experience respiratory issues with poor air quality; species of all sorts, domestic to wild, are also affected. Birds are especially harmed by atmospheric pollutants, such as with "the canary in the coal mine" example, with results yet unknown in long-lasting smoke-filled air. And with the continuing precipitous rise in climate pollution causing biodiversity to plummet at even faster rates, this otherwise offsetting support creates additional negative consequences for human well-being.
As regards the evaluation of potential mitigation and displacement for methane pollution contained in this supplemental analysis, the conclusions are still misleading and concerning in its reliance on speculative – such as when and how much methane will leak - and unenforceable – such as presuming a single source gas from British Columbia (referencing the breakdown experienced last year) - assumptions. To allow such conclusions to elicit a statement from NWIW, claiming that "Ecology's best estimate is that NWIW's Kalama facility will result in a global net reduction of over six million metric tonnes of GHGs every year" is tantamount to giving the green light to this project, when in reality, no such reduction can be presumed, let alone expected.
This proposed facility, if allowed its permits, will cause millions of tons of greenhouse gas pollution each year, for 40 years. Regardless of the fact that this choice is antithetical to Washington State's legislated carbon emission goals, it brings on a future which will compromise the health and even kill, thousands of Washington State residents, along with the region and nation. Our choices today determine what happens tomorrow.
Morally, ethically, scientifically and practically, you must reject this proposed plant which will become our State's greatest source of climate pollution, adding to the degradation of the public good and diminishing the quality of life to all of its species.

Sincerely,
Anne Kroeker

No attachments

Comment From: Mike Reuter

10/09/20 @ 8:02 AM
I am speaking here as an individual and not as the Mayor of Kalama.

Questions about the company's spokesmen having concerns were already being looked into years ago.

Methanol proposal arrived in Tacoma after extensive Inslee ... The newstribune
Apr 9, 2...↓

Email records obtained by The News Tribune show the proposal arrived in Olympia with high-caliber names on board: an acquaintance from the governor's years in Congress and a controversial Chinese political scion.
The acquaintance, California businessman Mike Tao Zhang, worked for Northwest Innovation Works. He introduced the project with a March 2013 email to Inslee staff member Sam Ricketts, who passed it along to other administration officials. Zhang wrote of "clean energy plants" slated for somewhere in the Pacific Northwest.

Attached were photos of what Zhang called "the good old time" he and Inslee had at a Washington, D.C., meeting in 2009, during Inslee's time in Congress.

Zhang, who is no longer affiliated with Northwest Innovation Works, declined via email to answer further questions.

In the email, he wrote the joint effort of China's government and the oil giant BP (which since has sold its interest) had made "good progresses (sic) in Oregon," including meetings with then-Gov. John Kitzhaber about possible plants there. The company, he added, would rather build in Washington to save money on piping in natural gas.

He also dropped a heavyweight name: Jiang Mianheng, the son of former China president Jiang Zemin. A follow-up email identified Jiang Mianheng, then a top official within the Chinese Academy of Sciences, as "the sponsor of our company" who was headed soon to the United States to gin up business deals.
It did not mention a series of news stories the year before that identified Jiang Mianheng as a "princeling" whose connections had made him millions as a businessman.

Less than a month after the email was sent, the New York Times won a Pulitzer Prize for China-related stories the prize committee labeled a "striking exposure of corruption." The series included a May 2012 report on how Jiang Mianheng had profited from his family name despite China's laws to prevent leaders' families from accumulating power and wealth.

Mike Tao Zhang-

President of Hoku Materials Inc
Hoku Materials, made the Chapter 7 filing Tuesday, the Idaho State Journal reported.

Hoku Materials started building the $700 million plant five years ago as interest in solar energy grew and polysilicon prices rose. The company said it would bring hundreds of higher paying jobs to Pocatello.
Board Director of the Hoku Corporation

Financially troubled Hoku Corp. announced today that it has completed its voluntary delisting NASDAQ Global Market.

09-28-2016
INDUSTRIAL PIPING, INC., Plaintiff, v. WEI XIA,TAO (MIKE) ZHANG, DAYI (SEAN) LIU, and TIANWEI NEW ENERGY HOLDINGS CO., LTD., Defendants.

Jiang Mianheng

Son of Former Chinese Leader Jiang Zemin Said to Be Under House Arrest
BY LARRY ONG September 29, 2016

Jiang Mianheng, the elder son of former Chinese Communist Party chief Jiang Zemin, is presently under house arrest, according to a source close to the Party disciplinary inspection branch in Shanghai.

The source told the Chinese language edition of Epoch Times that Jiang is being held under house arrest in a secret location on the outskirts of Shanghai. He is only allowed outside the residence for fresh air, the source said; the source said he had personally seen Jiang at the location, using an "observation device" to confirm a tip-off.

The detention of Jiang Mianheng by the Party's anti-corruption investigators is the culmination of probes conducted over about the last 18 months into prominent companies and institutions that Jiang is associated with. The development also points to the possibility that Party leader Xi Jinping's intends to bring the anti-corruption drive to its endgame, with the arrest and punishment of the senior Jiang, whose effective control over the communist regime extended until 2012.

The Shanghai disciplinary inspectors want from Jiang Mianheng a complete account of his personal and family financial affairs, the source, who is close to the investigators, told Epoch Times. Based on what inspectors currently know about the Jiang family's property, assets, and wealth secured through illegitimate and obscure means, the source said, "it's enough to feed and water the Chinese people for several years; the figure is eye-popping!"

I have questions about the team at NW Innovation Works experience and why these two people were chosen to be the president and vice president when NW Innovations was brought to the NW.

I wonder why the company didn't hire an ex-executive from a methanol refinery, or even someone at least worked for one. This is why I believe that it was a speculative venture from the get-go.

Governor Inslee Briefing Memo 1 FROM: Schuyler Hoss PHONE: 360-239-1317 MEETING: MEETING WITH REPRESENTATIVES OF THE CHINESE ACADEMY OF SCIENCES DATE/TIMEFebruary 12, 2015 11:30 am to 11:50 am LOCATION: ATTACHMENTS: Governor's Office Tan Tieniu, Deputy Secretary-General of the Chinese Academy of Sciences and the Director General of the CAS Bureau of International Cooperation 2. Wu Lebin, Chairman, China Academy of Sciences Holding Company 3. Simon Zhang, CEO, CECC and NW Innovation Works 4. Vee Godley, President, NW Innovation Works 5. Joe Smith, Vice President, NW Innovation Works 6. Charla Skaggs, NW Innovation Works 7. Ed Sapin, NW Innovation Works 8. Rick Desimone, NW Innovation Works 9. Mei Zhang, NW Innovation Works

Murry "Vee Godley President of NWIW

According to an article called -Meet Northwest Innovation Works January 22, 2014

Northwest Innovation's president is Murry "Vee" Godley 54, a North Carolina native who said he has more than three decades experience in the construction industry.
This is his first methanol project, but he is hiring a team with experience in the industry.

On linkedin it lists prior experience

1993-2005

Vice president Luwa Mechanical Specialties. Luwa Mechanical Specialties is a plumbing, heating and air conditioning company.

2010-2013

Sr. Project Director-Industrial Piping Inc.-

2013 to present

Chief Development Officer-Pan Pacific Energy- The parent company of NWIW-

2014 to present
Chief Development Officer- NW Innovation Works

Joe Smith vice president NW Innovation Works

Linkedin information

Specialties: documentation, forklift operator, graphic design, ids, leadership, mark, organizational skills, personnel, process engineering, repair, supervisory skills, swing, technician, training, training materials, upgrades

Experience
D&L Foundry

Safety Manager
Company Name D&L Foundry
Dates Employed Mar 2019 – Present
Employment Duration 1 yr 8 mos
Location Richland/Kennewick/Pasco, Washington Area

NW Innovation Works

Vice-President
Company Name NW Innovation Works
Dates Employed Jan 2013 – Sep 2017
Employment Duration 4 yrs 9 mos
Location Vancouver, WA

Hoku Materials

Dates Employed Jan 2009 – Aug 2011
Employment Duration 2 yrs 8 mos
Currently working with commissioning team. While working with the commissioning team, I will be creating procedures and commissioning procedures, reviewing P&IDs, working with engineers and attending model reviews and Hazops for each of the processes in the plant. Organizing with construction for turn over packages. Overall goal with being with the commissioning group is have a documentation and be organized and ready to commissioning and start up the new process equipment.
Skills
When I was working for ASIMI, I was asked to travel and help Commission a new 800 million dollar plant, in which I spent a total of nine weeks during the commissioning and start up.

Hoku Corporation

TCS Production Project Manager
Company Name Hoku Corporation
Dates Employed Feb 2009 – Jan 2011
Employment Duration 2 yrs
Location Pocatello, Idaho Area

AE Polysilicon

Technology Superintendent
Company Name AE Polysilicon
Dates Employed Oct 2007 – Feb 2009
Employment Duration 1 yr 5 mos

Weyerhauser

Supervisor
Company Name Weyerhauser
Dates Employed Jul 2003 – Jul 2007
Employment Duration 4 yrs 1 mo
During my time at Weyerhauser my job was working on swing shift and direct the maintenance work and also the shift cleaning crew. The shift cleaning crew cleaned and maintained the machine. My accomplishments at Weyerhauser was to center line the machine so setup time was reduced and the cost of manufacturing was also reduced. The goal was accomplished by showing team leadership as well listen to the operators by setting all dials to a (ZERO) mark which would allow them to be able to run a one box setup.

REC Silicon 5-29-07- 10-03-07

(REC Silicon ASA is fast approaching its effective exit from the solar market after revealing in its second-quarter update it had sold off the last 62 MT of PV-grade poly produced at its plant in Moses Lake, Washington, which has been shuttered for over a year.)

Currently working with commissioning team. While working with the commissioning team, I will be creating procedures and commissioning procedures, reviewing P&IDs, working with engineers and attending model reviews and Hazops for each of the processes in the plant. Organizing with construction for turn over packages. Overall goal with being with the commissioning group is have a documentation and be organized and ready to commissioning and start up the new process equipment.

REC Solar

Plant Trainer
Company Name REC Solar
Dates Employed 1989 – 2006
Employment Duration 17 yrs

ASiMI

Feb 11, 2005

Company Name ASiMI
Total Duration 15 yrs 2 mos
Title Plant Training coordinator
Dates Employed Feb 1997 – Jun 2003
Employment Duration 6 yrs 5 mos
My job while doing the training coordinators job was not only to develop training materials for the plant but also train all plant personnel as well as tracking the training performance.

• Title Research and Development Team leader

Dates Employed Jul 1996 – Feb 1997
Employment Duration 8 mos
To develop a new process to make the same product but faster and using less people.
This including traveling to different vendors to insure proper equipment would come to the plant. This also included commissioning a new section of the plant. Which included developing new operating procedures.

• Title Silane Operator

Dates Employed Nov 1988 – Jul 1996
Employment Duration 7 yrs 9 mos
Monitor equipment, lock and tag out equipment. Clean and prepare equipment for maintenance. Pull sample for the lab. Complete minor repairs such as change valves and rebuild sample station.
To become a certified operator in the Silane Unit you went through a three year certification program with included but not limited to drawing sketches of equipment and location taking writing test and test your skill by actually completing the task. During my time as a silane Operator I became a Supervisor Upgrade. That included during an incident in the plant I became the incident commander and would take control of the emergency and call all approiate people. Also during my time as a Silane Operator I was asked to go to Butte Montana to help start up the new facility.

• Title Reactor Technician

Dates Employed May 1988 – Nov 1988
Employment Duration 7 mos
Remove product from reactors (poly silicon). In order to remove the product we must have been certified to use the overhead cranes. Also this job required you to become certified as a reactor technician I completed it within two months.

No attachments

Comment From: Richard Desimone

10/09/20 @ 7:37 AM
Attachments:

Comment From: Thomas Gordon

10/09/20 @ 7:37 AM
There are many problems associated with the proposed methanol refinery to be built in Kalama.
One is the amount of methane released from the fracking sites in Canada and the United States to transport to the refinery in Kalama. The number of sites wh...↓
Sight Line, on September 23, 2020, suggests a solution.

"The only way to accurately capture methane leakage like this is to use satellite-based "top-down" methodology, which the Kalama SSEIS dismisses. And adding insult to injury, the SSEIS also uses a global warming potential for methane about 30 percent lower than the figure recommended by the IPCC's most recent report, which has the effect of further downplaying the Kalama project's climate problem."

However, wild fires rage to our south in California, Oregon, and here in Washington, made much worse with the drying from drought caused by climate change. The best solution seems to me to not build this methanol refinery with its attendant pollution from the manufacture of methanol. The pollution is not minuscule: it is expected to be in the millions of tonnes according to the SSEIS. Why should we put our homes in even more danger with exacerbated levels of green house gases from this unnecessary refinery?
Please deny the permit and project and not endanger our homes more.

No attachments

Comment From: Nancy Danoff

10/09/20 @ 7:32 AM
As a pediatrician, I am concerned that the proposed Kalama methanol plant will be the source of leaked methane, which is many more times potent than carbon dioxide as a greenhouse gas. As the Pacific Northwest has faced unprecedented wildfires and re...↓

No attachments

Comment From: Diana Gordon

10/09/20 @ 7:31 AM
I am very concerned about the amount of greenhouse gases that will result if the Kalama methanol refinery is built. The GHG's are a real problem, especially if the methanol is used largely for vehicle fuel instead of for plastic, as we suspect it wi...↓

The proposed refinery in Kalama will increase Washington's greenhouse gas emissions and make it harder for us to meet our GHG emission goals as set by our legislature in 2008. In addition to the sizable amounts of methane that will result from fracking, the pipelines, and the plant itself, the refinery will also release more than 1,000,000 tons of carbon dioxide every year, among other things. The huge ships transporting the product to Asia will also be responsible for considerable releases of CO2 from fuel combustion.

The problem is that CO2 combines with water to create a mild acid which affects the ability of shellfish to form shells. This acid affects oysters and, even more important, shell-forming marine plankton which is critical in basic marine food chains. These effects start in the higher latitudes and gradually move toward the equator.

Ocean acidification is a huge problem for the economy of our state. It affects one of our major industries, one that earns an estimated $270 million a year for the state coffers, the shellfish industry. People expect outstanding seafood when they visit Washington State or buy oysters from here. More and more we are hearing that oyster farmers are in trouble. Some have already moved to the less acidic waters of Hawaii. 

This project will have significant adverse environmental impacts here in Washington State and around the world. Coral reefs, an important support system for fish stocks, and marine food chains will suffer as a result of further ocean acidification. 

This terminal is counter to the economic interests of just about everyone except the Chinese and the Canadian oil industry. It will cost Washington and the Pacific Northwest jobs from the fishing industry and affect the ability of the oceans to produce food used around the world. 

Anthropogenic greenhouse gas emissions have been one of the major drivers of climate change so far. This year alone, in real time, we have witnessed drought-driven wildfires with adverse health effects, extraordinary wind events, early hurricanes and floods, etc., and we have had less than 1 degree C of global temperature rise. We are about to add more major food shortages if we do not get a hold on the acidification of the oceans.

We cannot ignore these harmful and unmitigable outcomes if we go ahead with this project. Please deny the Shoreline Permit for this extremely dubious venture.
No attachments

Comment From: Sariah Zambrano

10/09/20 @ 7:14 AM
I am a birdwatcher and outdoorsman who loves my state for her glorious natural wonders. Please deny the construction of a methanol/fracked gas facility in Kalama, Washington. I depend on the aquifer that would be affected by this methanol plant for m...↓

"No" to Kalama Manufacturing and Marine Export Facility.
No attachments

Comment From: Port of Kalama (Mark Wilson)

10/09/20 @ 7:09 AM
Comments from the Port of Kalama are contained in the attached letter.
Attachments:

Comment From: Margo Rolf

10/09/20 @ 7:06 AM
Please do not permit the construction of the Kalama Methanol plant. The use of vast quantities of fracked gas will present major danger to our environment and will contribute to disastrous change to our global climate. It will require more gas than ...↓
No attachments

Comment From: David Hupp

10/09/20 @ 6:42 AM
Washington State Department of Ecology:

I testify yet again in opposition to the proposed Northwest Innovation Works (NWIW) Kalama Manufacturing and Marine Export Facility in any form. This is a followup to my previous comments, dated September 19 and...↓

I am taking the unusual step of submitting the content of another's comments already submitted to you. My purpose is to make sure you do not miss the vital and essential points Linda Horst is making. She reveals that NWIW is a shell corporation playing a shell game and has taken the trouble to dig out information that Washington State government should have already considered and highlighted. In this I urge what in business is called "due diligence".

Linda Horst has already submitted the following:

Note to Ecology:
Admittedly, the following comment listed below does not critique GHG emissions, displacement or mitigation issues. My comment will, however, address the bona fides, or lack thereof, for Northwest Innovation Works to reliably and fully implement during the next 40 years their commitments contained in the DSSEIS: lowering GHG emissions; displacement of other dirty fuels; and 100% mitigation of all in-state direct/indirect GHG emissions.

The saying "All hat, no cattle" comes to mind when I consider the role of Northwest Innovation Works in their high-stakes, paper shell game they are waging with Ecology in this Draft SSEIS process.

While Ecology has invested considerable time and money researching and analyzing the myriad aspects and ramifications of this proposal, alarmingly zero attention has been devoted to the qualifications of the proponent of this climate/life altering refinery!

It is unconscionable that this upstart company that has never built a methanol refinery, never operated a methanol refinery or ever produced a drop of methanol is, in fact, proposing to build, operate and produce methanol in what would be the largest fracked-gas-to-methanol refinery in the world! Too ludicrous to be true? Tragically it appears not to be too ludicrous for every governmental agency in Washington state that has been tasked with reviewing this proposal for the past 6 years!

How did this meritless company get this far?

NORTHWEST INNOVATIONS WORKS LLC:

• No employees — according to WA Secretary of State, NWIW Kalama LLC has no active license with L & I — no covered employees

• No income — since forming their LLC, zero income from methanol sales

• No assets — business office rented not owned

• No credentials — no documentary evidence

• No experience building a methanol refinery

• No experience operating a methanol refinery

• No EPA approval for the ULE technology proposed to decrease GHG emissions

• No methanol refinery has ever used both ULE and ZLD technology together

They say "The devil is in the detail". The preceding "No —" details are red flags I trust Ecology will not ignore.

There are almost as many red-flag comments submitted against this refinery proposal as red-shirted "No Methanol Refinery" opponents! All of us urge you to deny this permit.

Submitted in support of Linda Horst's concerns,
David Hupp
Hood River OR
October 9, 2020
No attachments

Comment From: Rebecca Nimmons

10/09/20 @ 6:34 AM
Thank you for your work to protect Washingtons environment and acknowledgement that previous environmental analysis of Northwest Innovation Works (NWIW) Methanol refinery proposal in Kalama, Washington have been inaccurate and inadequate.

This new Dra...↓

Despite these marginal improvements, the evaluation of potential mitigation and displacement contained in this analysis is misleading and concerning in its reliance on speculative and unenforceable assumptions. One can simply look to the impacts of this pandemic to see evidence of incredible uncertainty and volatility in energy market dynamics. It is dangerous to presume this analysis can accurately predict global fuel markets, technology developments, consumer behavior, or regulations for the coming four decades. Furthermore, the SEIS provides too little detail on the actual mitigation that would be accomplished within the voluntary mitigation framework, nor does this mitigation address the full impacts of NWIWs emissions that will occur overseas. The mitigation framework is too vague for Ecology to conclude that this projects impacts will be mitigated, and the urgency of climate change demands that mitigation should be the last option (after all other impacts are reduced) in order to address unavoidable impacts, not simply to maintain the status quo as we continue to build out the fossil fuel industry.

Even with all of its flaws, this analysis confirms that NWIWs proposed facility would become one of the greatest sources of climate pollution in Washington. It is simply unacceptable for Washington to build an unequivocally and enormously polluting facility based on speculative analysis and a faint hope of theoretical emission reductions. Ecology should dismiss the speculative basis that this project could displace even more polluting facilities, and instead should base its permitting decision on what is reasonably foreseeable and indeed, assured, about this project--that it would cause millions of tons of greenhouse gas pollution each year, for 40 years, and is profoundly inconsistent with achieving Washingtons climate goals.

The evidence in this draft SEIS demonstrates that Washington should deny NWIWs proposal to build and operate this dangerous methanol refinery in Kalama. We cannot keep building fossil fuel export infrastructure and expect to address the dangers of climate change.

Please keep our communities safe and keep Washington on track to meet our goals for reducing climate pollution.
No attachments

Comment From: Donald Watt

10/09/20 @ 6:15 AM
The Kalama Methanol Plant proposal is a horrible idea for Washington, for the Columbia River, and for our planet. But even more than that, the Kalama proposal represents a Pandora's Box of destructive precedents that it would set for our region and ...↓
We would be horribly naive to think that the Kalama Methanol proposal would be the last request to expand exports of fossil fuel energy to supply markets in Asia, or that it would be the last request to build new petrochemical facilities along the shores of our beautiful lower Columbia River, or that it would be the last time the fossil fuel industry would pressure the Department of Ecology to allow a massive increase in greenhouse gas emissions.
No! If approved, in each of these cases the Kalama Methanol Plant proposal would prove to be just the first in a long list of proposals for projects that would further degrade our river, our region and the climate of our planet.
Left unchecked, the fossil fuel and petrochemical industries could easily turn the Columbia River, between Portland and Astoria, into a new "Cancer Alley" rivaling what we see along the Mississippi River between Baton Rouge and New Orleans. Producers of petroleum from the Alberta tar sands and Bakken oil shales and of fracked gas from British Columbia are desperately seeking shipping routes to bring their products to markets in Asia. The Columbia River would provide that route along with abundant fresh water to feed their industrial processes.
Sadly, all of that development would come at a horrible price through the loss of the unique ecosystems of the lower Columbia and by sacrificing the livability of this beautiful region. As residents of this state and of this uniquely beautiful part of the world it is our duty to do all that we can to protect these natural treasures from the predatory forces of the fossil fuel industry. If we do not act to preserve these treasures that we have inherited, no one else will. There may be no second chances.
If the Department of Ecology is serious about protecting the environment in this region and serious about limiting greenhouse gas emissions then it must deny approval of this Kalama Methanol Plant proposal. Approval of this proposal would set a horrible precedent for future, increasingly destructive proposals.
The proposed site at Kalama is a prime industrial location. However it does not have to be used as a welcome mat announcing that the Columbia River is open for business for the destructive fossil fuel and petrochemical industries.
Please live up to your calling as protectors of the natural environment of the State of Washington please reject this Supplemental Environmental Impact Statement for the Northwest Innovation Works Kalama Methanol proposal.

No attachments

Comment From: Daniel Serres

10/09/20 @ 5:40 AM
Please see the attached collected public comments gathered through postcards and online through our website.
Attachments:
Download
Download

Comment From: Northwest Gas Association (Dan Kirschner)

10/09/20 @ 5:39 AM
Please see uploaded file
Attachments:

Comment From: Stacy Neal

10/09/20 @ 5:23 AM
Thank you for your work to protect Washingtons environment and acknowledgement that previous environmental analysis of Northwest Innovation Works (NWIW) Methanol refinery proposal in Kalama, Washington have been inaccurate and inadequate.

This new Dra...↓

Despite these marginal improvements, the evaluation of potential mitigation and displacement contained in this analysis is misleading and concerning in its reliance on speculative and unenforceable assumptions. One can simply look to the impacts of this pandemic to see evidence of incredible uncertainty and volatility in energy market dynamics. It is dangerous to presume this analysis can accurately predict global fuel markets, technology developments, consumer behavior, or regulations for the coming four decades. Furthermore, the SEIS provides too little detail on the actual mitigation that would be accomplished within the voluntary mitigation framework, nor does this mitigation address the full impacts of NWIWs emissions that will occur overseas. The mitigation framework is too vague for Ecology to conclude that this projects impacts will be mitigated, and the urgency of climate change demands that mitigation should be the last option (after all other impacts are reduced) in order to address unavoidable impacts, not simply to maintain the status quo as we continue to build out the fossil fuel industry.

Even with all of its flaws, this analysis confirms that NWIWs proposed facility would become one of the greatest sources of climate pollution in Washington. It is simply unacceptable for Washington to build an unequivocally and enormously polluting facility based on speculative analysis and a faint hope of theoretical emission reductions. Ecology should dismiss the speculative basis that this project could displace even more polluting facilities, and instead should base its permitting decision on what is reasonably foreseeable and indeed, assured, about this project--that it would cause millions of tons of greenhouse gas pollution each year, for 40 years, and is profoundly inconsistent with achieving Washingtons climate goals.

The evidence in this draft SEIS demonstrates that Washington should deny NWIWs proposal to build and operate this dangerous methanol refinery in Kalama. We cannot keep building fossil fuel export infrastructure and expect to address the dangers of climate change.

Please keep our communities safe and keep Washington on track to meet our goals for reducing climate pollution.
No attachments

Comment From: Brian Blake

10/09/20 @ 5:21 AM
Throughout my career, whether as a logger, an environmental specialist, or a legislator I've seen the people of southwest Washington work hard to balance their strong sense of community and pride they take in the natural beauty of our area with the n...↓

This project has been under intense review for nearly six years. The company and its regulators have proceeded with full transparency and the public has been meaningfully involved in process every step of the way. Like most big projects, this one has attracted some opposition � that's part of the democratic process.

My friends in the progressive and environmental activist communities should take pride in knowing that their aggressive advocacy around this project has meant that we have all the facts to know that moving forward with this project is not just good for jobs, but good for creating a more sustainable and accountable system to measure climate change impacts and mitigate for them. NW Innovation Works' project meets the tests needed to move forward: we have all the facts, we know the impacts on our community, and we know that building the project will reduce the release of greenhouse gas emissions associated with manufacturing the products we all use every day.

The Department of Ecology's Second Supplemental Environmental Impact Statement details how building the Kalama methanol facility will result in a net reduction of 6 million metric tonnes of greenhouse gas emissions annually, which is equal to eliminating approximately two times the number of GHGs as the entire city of Seattle emits annually.

I have worked hard, on a bipartisan basis, with my legislative colleagues to ensure that the Washington State Department of Ecology's review of this project was both thorough and timely. With the just released Draft Second Supplemental Environmental Impact Statement, I think the Department has met those goals. After receiving comments and completing the response process, there should be no further delay in finalizing the analysis and issuing all necessary permits. I intend to continue to work with my legislative colleagues to hold the Department accountable in this regard.

While Cowlitz County has rebounded from the deepest parts of the recession to a certain degree, it has been left behind the economic boom that much of the state is experiencing. Many of the county's economic and social indicators lag behind the rest of the state, which can be traced to a lack of access to good, family-wage jobs.

Southwest Washington historically has one of the highest unemployment rates in western Washington. The latest statistics indicated that the county's labor force participation is substantially lower than the national rate and that average annual wages are well below the state and national averages. Too many Southwest Washington families live in or near levels of poverty. The problem is especially acute for children with far too many living in poverty. Southwest Washington has significantly higher rates of poverty for the same cohorts for the state as a whole.

This lack of opportunity and the stresses families face in Southwest Washington result in impacts to school readiness and other social determinants. As an example, less than a third (30%) of Cowlitz County children are assessed to be kindergarten ready when measured by the WaKIDS' six domains. This compares to 47% for the state overall.

Many project opponents who don't live in Southwest Washington seem to think that these statistics will somehow, magically get better on their own, or they ignore them. They won't get better on their own and we can't ignore them.

Jobs make a difference for communities. Cowlitz County does not have enough good paying jobs. We need to create more. NW Innovation Works will create the right kind of jobs for our community.

The project is estimated to create 1,000 jobs during construction, 200 direct permanent family wage jobs during operations, and 500 indirect and induced jobs. They will support $700 million in local spending on labor, goods, services and produce $21 million in annual salaries - a significant percentage spent at local businesses.

NW Innovation Works is committed to local jobs and has agreed to a Project Labor Agreement with the Longview/Kelso Building and Construction Trades, along with the full support of the Washington State Building and Construction Trades Council and the Cowlitz/Wahkiakum Central Labor Council. This means that local Trades people are guaranteed the first chance at work opportunities on this project. Local workers making a family wage translates into the investment dollars spent on this project staying in the community and supporting the local economy. Increase in apprenticeship opportunities for our local youth, unemployed or underemployed community members.

And NW Innovation Works has planned partnerships with Lower Columbia College, Workforce Southwest Washington, and the Cowlitz County Economic Development Council to establish a program for training and hiring permanent employees from the local community that will include full tuition and stipend for students who are accepted into the training program and full-time living-wage employment at the facility upon program completion.

NW Innovation Works is investing in the community. Increased local spending will grow small businesses, increase land and property values and enhance overall opportunity & quality of life for residents. And the project will generate much needed tax revenue. NW Innovation Works has neither requested nor received changes in tax law or special tax treatment to build in Cowlitz County. The company will pay an estimated $57.9 million in taxes during construction and $30-40 million in annual taxes during operations which will further enhance the quality of life for local residents and their families - New community facilities, enhanced community services and infrastructure & improved local schools.

These are meaningful benefits that cannot be substituted for by rhetoric or good intentions.

Climate change doesn't respect borders. It is a global issue and our response to it must be done in a way that recognizes we are all in this fight together.

The Department of Ecology's report confirms that we are in a time of large and rapid increases in global demand for methanol. Nowhere is demand for methanol rising faster than in China. China consumes approximately 50% of the world's methanol and approximately 80% of the methanol China produces is derived from coal. The Chinese government has continued to promote efforts to use their abundant coal resources for high value industries, notably, the chemical industry.

If we don't help to meet that demand here � in an environmentally sound way � that demand will be met by someone else � probably in the Middle East, Russia, or China. That's not conjecture. That's a fact.

And what we know from the Department of Ecology report is that by producing the methanol in Kalama at NW Innovation Works' facility, we will reduce greenhouse gas emissions. If we let others do it, those emissions will go up. Why would we pick that? The answer is, we shouldn't.

We now know, from the highest environmental regulatory authority in the state all that we need to know about this project. We are a state with tough environmental standards. This project meets those standards.

Opponents should join project supporters in understanding the bottom line facts regarding the environmental benefits moving forward with this facility means and embrace the progress represented by the project. Efforts to further delay this project means two things: bad outcomes for the working families of southwest Washington and bad outcomes in our fight against climate change.

No attachments

Comment From: Russell Jacobson

10/09/20 @ 5:17 AM
Please reject this project. We need to be moving away from fossil fuels but this plant would lock us into fossil fuels instead. It would use an enormous amount of water from the Columbia and Kalama River aquifers just at a time when water usage and s...↓
No attachments

Comment From: Lucy Pierce

10/09/20 @ 5:09 AM
I am a retired teacher from the Longview School District and own my own home here in Cowlitz County.

The proposed Kalama methanol refinery is a 2.1 Billion project � That's Billion with a "B." By asking for a federal guaranty loan, NWIW, a Chinese-ow...↓

I would also like to know why it is that Washington State and County governments are offering approximately $143 Million in tax incentives without any "clawback" provisions written into the deal so that if NWIW doesn't come through (in providing the number of local jobs and pay rates that they have promised to our community), we don't have to honor the $143 Million in tax incentives. What incentive does NWIW even have to provide the promised number of jobs, salaries, etc. without a clawback provision? Other states and cities in similar positions have insisted on clawbacks... Why are our local leaders so afraid to do the prudent thing and demand them?

Lastly, the proponents of the refinery are making wild speculations about net climate benefits, because it assumes that China will use the methanol to replace dirtier coal. We have NO assurance that that will come to pass. We have NO way to measure whether the Chinese are in fact, reducing their usage of coal-derived-methanol. They have not made any concrete agreement with us that they will in fact replace any coal-derived methanol, and even if they did, we'd have NO way to enforce said agreement. Most likely, they will simply ADD this new supply of methanol to their current activities, not replace any "dirtier" form of consumption.

No attachments

Comment From: Sheri Jacobson

10/09/20 @ 5:06 AM
I urge you to reject this project. Annual emissions from the manufacturing process alone would add over a million tons of carbon pollution to our air. It would also emit hazardous chemicals like ammonia and nitrogen oxide. It will use government fund...↓
No attachments

Comment From: Sheri Jacobson

10/09/20 @ 5:06 AM
I urge you to reject this project. Annual emissions from the manufacturing process alone would add over a million tons of carbon pollution to our air. It would also emit hazardous chemicals like ammonia and nitrogen oxide. It will use government fund...↓
No attachments

Comment From: John Flynn

10/09/20 @ 5:05 AM
Department of Ecology
KMMEF-Draft SSEIS
In reviewing the Draft SSEIS for the proposed KMMEF methanol refinery I was disappointed to find no reference whatsoever to the negative impacts of ocean acidification from greenhouse gas emissions and CO2 absorp...↓
In February of 2012 then Washington Governor Christine Gregoire convened the Blue Ribbon Panel on Ocean Acidification and tasked that panel to produce a set of recommendations to guide Washingtons response to ocean acidification. The results of the panels findings were submitted to the Governor on November 27, 2012.
A technical document titled "Scientific Summary of Ocean Acidification in Washington State Marine Waters" was created. This document was the foundation for the Panels report "Ocean Acidification:From Knowledge to Action, Washingtons State's Strategic Response".
On November 27, 2012 Governor Gregoire signed Executive Order 12-07 directing the Department of Ecology to implement the recommendations of the Panel, which listed as its number one priority the reduction of carbon dioxide (greenhouse gas) emissions.
In December of 2017 an addendum was released that expanded upon the original 2012 report by the Blue Ribbon Panel on Ocean Acidification. All of these documents can be found on the Department of Ecology website. They are an integral part of Ecology's mandate to protect and preserve Washingtons environment. Ecology must abide by the mandate given to them.
My question to Ecology is why is there no mention of or reference to the impacts of an estimated 4.6 Million Metric Tons of greenhouse gas emissions per year from the proposed Kalama methanol refinery and its effects on ocean acidification? The Department of Ecology was and continues to be involved in studying the impacts of ocean acidification from CO2 absorption resulting from greenhouse gas emissions. Therefore, it is only logical to conclude, that ocean acidification as a result of greenhouse gas emissions would be part of any analysis included in the Draft SSEIS.
I ask the Department of Ecology to not be derelict in their duty to include these impacts in their SSEIS. I am confident that if the Department of Ecology seriously looks at the negative economic and cultural impacts of ocean acidification to commercial, recreational and tribal fishermen and women resulting from the greenhouse gases emitted
from this proposed project they will categorically deny any and all permits for the proposed Kalama methanol refinery.
Do your duty and deny this project.
Thank you.
No attachments

Comment From: Diana Gordon

10/09/20 @ 5:03 AM
I think there is real reason to doubt that the methanol from the proposed Kalama refinery will be used to produce plastics. I fear that it, or a large portion of it, will be used as vehicle or other fuel instead.

The reason is straightforward. There...↓

I think that China will decide that it makes more sense to go with the cheapest methods and use the Kalama methanol for fuel. I doubt that they would build any new coal-to- methanol plants at this point - they have pollution problems as well as a climate plan to go carbon neutral by 2060.

Methanol burned as fuel produces more GHG's than using it to manufacture plastics: 2 CH3OH 3 O2 -> 2CO2 4H2O - so we get CO2 which stays in the atmosphere much longer than methanol and has long-lasting global warming effects. Added to that, methanol has only about half the energy density of gasoline and therefore about twice the volume of methanol would be used to go the same distance as gasoline.

Using part or all of this product as fuel would seem, then, that the Kalama refinery would really be a fuel refinery and should be referred to EFSEC and the Governor to decide if we want to dump this amount of GHG's into the atmosphere.

We cannot be sure exactly what the Chinese will do down the road. We do know, however, that, if they do not abide by their agreement, there is no Olefin Police Force to ride in to rescue the climate from the added and illegal GHG's.

The climate problems this year - uncontrollable fires, early hurricanes, a lingering and devastating drought to name a few and all caused or exacerbated by climate change - all signal to us that this is the wrong time and the wrong place for this refinery. It is our time and our responsibility to wrap our arms around Washington's climate goals. We must do what we can to make fossil fuels and greenhouse gases problems that we are actively making progress against.

Please deny the Shoreline Permit for this plant.

No attachments

Comment From: Regna Merritt

10/09/20 @ 4:59 AM
Please accept attached comments from Regna Merritt, PA and Thomas T Ward, MD

Attachments:

Comment From: Kirk Leonard

10/09/20 @ 4:49 AM
Washington state will be locked into decades of additional climate pollution from the proposed methanol refinery.

The speculation this project could displace coal in China is not adequate justification for the known pollution that will be released int...↓

If built, the Kalama methanol refinery would create an enormous increase in greenhouse gas emissions, moving Washington further away from achieving the climate goals for this state.

As a member of the Kalama community, I have a vested interest for the quality of life everyone can enjoy and be proud of. Please deny the permit.

I urge you, the Department of Ecology to honor your mission to Protect, Preserve and Enhance the environment for current and future generations.
No attachments

Comment From: Don Steinke

10/09/20 @ 4:40 AM
After reading the comment from Cowlitz County, I respond as follows:

As I understand it, SEPA includes ALL impacts, there is no such thing as going beyond your authority in terms of impacts or scope.

The impacts of Kalama Methanol are not likely to be ...↓
Say so in your SSEIS and reject the project.

No attachments

Comment From: Nancy Elbert

10/09/20 @ 4:38 AM
I was born and grew up in Longview, WA.

I do not believe the SEIS adequately addresses upstream pollution in the lifecycle study for the proposed Kalama methanol refinery. For instance, the refinery would increase the amount of natural gas moving thr...↓

Natural gas lines are known to have not insignificant leaks and even "smallish" sounding amounts of 1% - 3% escaping are extremely harmful for climate change due to methane being 50 times more greenhouse gas-producing than carbon dioxide. Don't forget also the harmful effects to people who are nearby. Infants and children do not have agency and cannot simply move away from the problem.

The natural gas feedstock is proposed to be sourced from fracking to take place in British Columbia, but in all likelihood that will not be enough and eventually it will also need to come from fracking in the Rocky Mountain States. Regardless of source, fracked gas is known to disturb bedrock, cause earthquakes, and most terribly of all: poison groundwater with chemicals that cause cancer, birth defects, miscarriage, and stillbirth. The SEIS does not adequately take into account the harm caused by fracking, especially because Life Cycle Associates, (hired and paid for by proponents of the refinery), carefully selected their statistics to paint a cheery but inaccurate picture of the long-term affects of the additional fracked natural gas that would be needed for feedstock to the refinery.

I ask that the following be taken into account when performing analysis of this proposed project: 1) climate effects of fracked gas; 2) climate effects of pipeline leaks (with realistic leakage rates) and 3) the many harms to nearby inhabitants where fracking is taking place and where there is leakage. If these three things are fully taken into account, you will understand why I oppose building this methanol refinery. Thank you.

No attachments

Comment From: Methanol Market Services Asia ... (Mark Berggren)

10/09/20 @ 4:21 AM
Please see attached letter.
Attachments:

Comment From: Dela Zitkus

10/09/20 @ 4:10 AM
2020 brought us the hottest January on record, the hottest May, and the hottest September. Ever. April and June came extremely close to breaking their records.

The whole argument for or against the methanol refinery comes down to whether you believe...↓

Since we can't force the Chinese to produce less coal-derived methanol, we should assume that this new methanol would simply be added to their current supply. NWIW's numbers are all based on the argument that this new refinery would displace current production of some coal-based methanol production. There is no basis for this argument. Since China is a sovereign government and not a U.S. territory, we can't tell them what to do. Once the methanol leaves for China on a tanker ship, it's gone. What they do with it is their business. NWIW may be singing a sweet tune now, but once the refinery is built, all bets are off. The only control we have is now. The only power we have is to not build this refinery. I urge the Department of Ecology to deny the permit.

No attachments

Comment From: Don Steinke

10/09/20 @ 4:06 AM
OK, my final comment.

I began commenting by thinking about impacts you left out that should be included in the SSEIS.

Now I turn to elements that were inserted by the proponent that should not be in the EIS and should be removed.

Remove the speculative,...↓

James Gus Speth from Yale, is a member of the National Academy of Sciences. He says that this planet will not be fit to live on, if we continue business as usual.

To include business as usual in your SSEIS is to accept our eventual destruction.

Remove the speculative, business as usual, market assumptions from the SSEIS.

No attachments

Comment From: Low Carbon Prosperity Institut... (Kevin Tempest)

10/09/20 @ 3:53 AM
Dear Mr. Doenges, authors, principal contributors, and relevant staff,

Thank you for the opportunity to offer both spoken and written comments regarding the Kalama Manufacturing and Marine Export Facility Draft Second Supplemental Environmental Impact...↓

I am including two attachments for consideration:

(1) A Cover Letter summarizing key findings of my review of the draft document;

(2) A Letter of Findings that goes into greater details on the key findings offered in this cover letter and a written version of my spoken comments;
These key findings include:

The DSSEIS sensitivity analysis indicates a high likelihood of between 2 and 9 MtCO2e/year more emissions in the absence of KMMEF, including "extremely limited" potential for emissions to be higher with KMMEF methanol. These results are similar to a December 2018 analysis by LCPI (likely range of 2.3 to 7.2 MtCO2e/year) despite using a distinct and independent methodology. Consistent results across different methodologies lend increased confidence to the forecast and likelihood of net avoided emissions.

Inclusion of in-state emissions mitigation would increase the high-end range of net avoided emissions. This likelihood would be more certain if Ecology made it a formal permitting condition. In addition, the most accurate projections of the power grid under the Clean Energy Transformation Act would increase confidence in and the likeliest range of net avoided emissions.

Under much faster emissions intensity decline of global methanol substitutes than Ecology's analysis considers, the general findings remain consistent: It is very likely that net cumulative GHG benefits will accrue with KMMEF methanol compared to without it. This finding, based on new analysis available in the associated Letter of Findings, holds even with conservative assumptions that in-state emissions mitigation is ineffective and KMMEF methanol emissions intensity does not improve while competing methanol does rapidly. The additional stress and boundary testing indicate net global benefits through at least 2049, and very likely through end of facility life, even against a benchmark of a deeply decarbonized global industry. Nonetheless, it would likely be inconsistent to assume a major movement across the global industry while KMMEF emissions intensity remained static. This is not a given, and efforts should be made to ensure that KMMEF methanol remains well ahead of the curve.

A preliminary analysis finds it highly unlikely that substituting KMMEF methanol for gasoline end-use would be prevalent enough to lead to a net emissions increase. The combination of conditions required for there to be a net emissions increase represent an extreme outlier scenario. Even so, methanol availability as a fuel should not be used as a justification to stop pushing forward on primary solutions to meeting the global climate challenge, such as electrification of transport and building end-uses. If fuel-use impacts are a concern, mitigation strategies that include accelerating electrification of transport and buildings should be considered under the proposed voluntary mitigation plan.

Thank you for your consideration of these key findings as they pertain to Ecology's decision-making process. I would be happy to follow-up regarding any questions that arise from the documents I am submitting or serve as a resource otherwise as you consider the range of GHG impacts associated with the KMMEF.

Sincerely,

Kevin Tempest

Attachments:
Download
Download

Comment From: Cathryn Chudy

10/09/20 @ 3:49 AM
Ecology did the right thing when "expecting" NWIW to provide accurate and truthful answers to relevant questions on the proposed Kalama facility. The current SSEIS released on Sept. 2 became necessary when Ecology's persistence met the stone wall of ...↓
The original proposal for a facility twice the size of Kalama, to be built and operated in Tacoma, stalled in part back in 2016 over failure of this same company to answer basic health and public safety questions posed by the public and the Port Commissioners at Tacoma. A replay of this failure by this company to truthfully, factually, fully and adequately answer questions about the scope,nature and impacts of this proposed facility in Kalama once again forced Ecology to pursue substantive answers to relevant questions.
What you did establish with this second supplemental EIS is that upstream, on site and downstream emissions will result in an INCREASE (not a decrease or removal)of climate pollution in Washington.
The "Hail Mary" that proponents are grasping at in order to make their dubious case with Ecology involves a diversion from reality by taking us down the yellow brick road to the OZ of speculation and "if/then" thinking, that somehow has been converted into a case for environmental gain where there literally, factually is none.
"Voluntary mitigation" may sound reassuring to some, but add on the convenient phrase "to the extent possible" and you have an empty promise that more than likely will disappear into thin air as profits are pocketed outside of Washington and our children and grandchildren inherit the climate pollution mess that cannot be wished or "mitigated" away so easily.
There are good reasons that our Governor Inslee has said clearly that he cannot support this methanol facility in our state, and his climate agenda supported by legislation has established climate goals that protect, not endanger, our children's future and the future of the next seven generations. Ecology can and should do all it can to act in accordance with those wise climate goals.
Ecology is the guardian of our air, land and water - you must not sign off on this proposal masquerading as a "climate solution" without betraying the trust we and those who come after us place in you.
I urge you to deny the Shorelines permit and reject this project once and for all.
No attachments

Comment From: Oregon Conservancy Foundation Anonymous

10/09/20 @ 3:16 AM
We are experiencing immediate, devastating impacts of catastrophic climate change right now, where we live, work, and play!

It is ironic that public hearings on this fracked gas to methanol and marine export terminal are being held just as we are for...↓

The only way we can protect our region from the increased frequency and intensity of these destructive climate fires and its toxic air pollution is to keep fossil fuels in the ground.

In spite of the illusive rosy picture presented by proponents, and the speculation (not fact) that deceptively conjectures unsupported conclusions about reducing global emissions some time in the future, your SEIS makes clear that the operation of this facility will in fact pump 4.6 million tons of carbon dioxide pollution a year into Washington, for each of the next 40 years. This subverts rather than supports Washington's climate goals and is simply unacceptable at every level.

The claim that this company (with a track record of lying to regulators and the public) will voluntarily "mitigate" negative impacts is not worth the paper it is printed on. Without specifics, the "voluntary mitigation" promise is a house of cards and as toxic as the air we breathe in the aftermath of raging climate fires that are predicted to grow worse over time unless we set policies and make decisions that direct us away from fossil fuel facilities like this one.

This facility sentences our children to decades of adverse costs that you, the guardian of our environment for this and future generations, can not in good conscience ask them to bear.

The Oregon Conservancy Foundation beseeches you to carefully examine the climate facts (not speculations) in your own analysis. We ask that you deny the Shorelines Permit and ultimately reject this methanol refinery, for the health, safety and long term well being of our children and the survival of biological life support systems on this planet.

No attachments

[ Previous Page / Next Page ]