Kalama Manufacturing and Marine Export Facility Second Supplemental EIS

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Comment From: Cathryn Chudy

10/09/20 @ 3:10 AM
I listened carefully to all who spoke during three virtual hearings. I was dismayed to be told that in opposing this proposed facility I am putting feelings over facts and ignoring science, that I rely on plastics and am a hypocrite for asking our D...↓

Feelings are essential when combined with facts that clearly show how this proposal will harm rather than help us, both in the short run and especially in the decades to come.

I see through the selective "science" advocated by proponents, that intentionally misleads and misrepresents, in order to reach conclusions that will somehow justify a "YES" outcome. A stronger case has been made by many of us that the "science," when not "cherry-picked, along with basic common sense, compels the Department of Ecology (the guardian of our land, air and water) to do the right thing for Washington by saying "NO" to both the Shoreline Permit and the proposed facility.

Plastic and methanol for fuel are end uses that we as stewards of the future for our children and grandchildren should be steering away from, rather than embracing. We can and will find alternatives that won't cost the health, safety and quality of life for the next seven generations.

As for maintaining the status quo, the Kalama proposal actually represents continuing a toxic "status quo" that advocates "business as usual, aka pursuing obscene profits for the few over harm to the many. We are asking for trying something different - saying "no" to fossil fuel profits in light of doing no harm.

Finally, I would not think to tell a child faced with a bully in front of him to let that bully land a sucker punch on his left or right eye, simply because there probably is another meaner bully around the next corner who will do worse. We should not tolerate this kind of reasoning to justify this facility, and neither should the Department of Ecology.

I urge you to deny the Shorelines Permit and ultimately reject the facility itself.

As Henry David Thoreau said:

"The cost of a thing is the amount of what I will call life which is required to be exchanged for it, immediately or in the long run."

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Comment From: Carole Eby

10/09/20 @ 2:50 AM
I implore you to reject the request for shoreline conditional use permits for the Kalama Methanol refinery. The SSEIS states that it "would increase greenhouse gases in Washington, but could substitute for dirtier sources of methanol globally". The o...↓

My husband and I bought property 6 miles south of the proposed methanol plant in January 1972. As friends and family helped us build this home the siren to warn us to flee a disaster at the Trojan Nuclear facility was being erected a few yards from our driveway. Kalama Chemical emits a stench that gives us nausea and headaches. We think of the spent fuel rods stored at Trojan. This is the legacy my children and grandchildren inherit. Please do not add this massive GHG polluter with speculative benefits.

I also call your attention to the issue of mitigating the alarming volume of greenhouse gases this plant will spew into the air we breathe. In an interview with the Daily News, Mr. V. Godley, speaking for NWIW expressed pleasure over being able to mitigate entirely in the State of Washington. Yet we know full well that the SSEIS says if the emission reduction obligation cannot be met with local or regional projects "the board will look to purchasing credits through established national or international carbon markets". Furthermore if the cost of those hypothetical local or regional mitigation projects can't be covered in the budget "then the reduction obligation is achieved with the purchase of carbon credits". The public has been fooled into thinking that full mitigation means all those greenhouse gases are being magically neutralized locally. Perhaps there's a bird refuge, nature path, or an acre of sapling trees in Kalama's future? You know this is intended to lull people into complacency.

Though not directly related to your request for comment on the GHG and mitigation issues, I wish to note the disingenuous nature of NWIW when it comes to the highly touted subject of 200 highly paid jobs. We have seen the lease agreement between the Port of Kalama and NWIW. They agreed that the requirements of the lease could be met with as few as 80 employees, and if circumstances dictated, NWIW has the option to negotiate with the Port for an even lower work force. We are tired of this spectacle of smoke and mirrors.

Climate change is real. This refinery doesn't belong in Kalama or anywhere else. Deny the permits. Speak to the best interests of people. Urge the Port of Kalama to focus on clean energy projects. Even when a project has hung about in the wings forever there is still time to say "no". Thank you for protecting our air and water, and our future.

Sincerely,
Carole Eby
1010 Martin's Bluff
Kalama, WA 98625

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Comment From: Carolyn Fox

10/09/20 @ 1:31 AM

I am opposed to the proposed Kalama methanol refinery. It will be a huge emitter of greenhouse gases and it won't stop anyone from continuing to mine coal and burn it. It will be a 'net addition' of greenhouse gases to the planet. Please do not is...↓

Thank you.

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Comment From: Ellen Mickle

10/09/20 @ 1:30 AM
Dear Washington Department of Ecology,
I strongly urge you to deny the Kalama methanol refinery project since, based on your own draft analysis, it would be a major polluter. It would use more fracked gas than all of Washington's gas plants combined. ...↓
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Comment From: Thomas Gordon

10/08/20 @ 5:32 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 1,100GW. 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 projects.
China's economic system is based on abundant and cheap capital being made available to the state-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 50 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 pollution.
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.
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Comment From: Thomas Gordon

10/08/20 @ 5:18 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 1,100GW. 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 projects.
China's economic system is based on abundant and cheap capital being made available to the state-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 50 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 pollution.
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.
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Comment From: Let's Build This (Tom Luce)

10/08/20 @ 5:00 PM
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 ...↓
  
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.  
Sincerely, 
Attachments:

Comment From: Cynthia Svensson

10/08/20 @ 5:00 PM
Dear Champions of Washington Ecology,

I just discovered another important GHG source while researching a question someone posed on Facebook.  It seems Japan has experienced, and is now concerned about, methanol tanker explosions.  That'...↓

 https://www.spglobal.com/platts/en/market-insights/latest-news/petrochemicals/061419-japans-mgc-weighs-options-for-methanol-cargoes-after-blast-on-kokuka-courageous-tanker-sources

Thank you,

Cynthia Svensson

MS Chemical Oceanography, U. of W.

Kalama resident
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Comment From: Diane Dick

10/08/20 @ 5:00 PM
Re: Comments on Draft Second Supplemental Environmental Impact Statement for

Kalama Methanol Refinery and Export Terminal

 

Dear Director Watson:

Greenhouse gas emissions are not fully accounted for in the draft second supplemental environmental imp...↓

Please deny Kalama Manufacturing and Marine Export Facility (KMMEF) a shoreline substantial development and a conditional use permit. The environmental impacts from the project are significant and cannot be mitigated.

1.  Include GHG emissions from construction and operation of Kalama Lateral Gas Pipeline.

In 3.4.2 Upstream emissions it is stated, “GHG emissions from the local natural gas distribution system are not attributable to the project because KMMEF will have its own dedicated high-pressure connection. As described in the First SEIS, natural gas will be supplied to KMMEF from the existing interstate transmission pipeline via a new 24-inch 3.1-mile lateral interconnection pipeline. Northwest Pipeline LLC is proposing to construct and operate this interconnection pipeline, which is known as the Kalama Lateral Project.”

Presently there is no high-pressure gas connection to the KMMEF site in existence. In the no build alternative to KMMEF there will be no Kalama Lateral pipeline. The Kalama Lateral is integral to the operation of the NWIW methanol refinery. Greenhouse gas emissions from the construction and operation of the Kalama Lateral Project should be included in KMMEF upstream and construction emissions.

2.  Upstream emission estimates are based on speculative, incorrect information and omissions.

To begin, over 99% of the natural gas feedstock source for upstream emissions is assumed to come from British Columbia, specifically the Montney Formation (FSEIS Appendix A, p. 41).

Fort St. John, BC, centered in the formation, is located 964 miles north of Kalama, WA.

The gas transmission pipelines map, Figure 3.4-1, labels the pipeline distance to the BC gas source as 629 miles. Clearly this is incorrect. The distance to a Wyoming gas source is likely similar or shorter.

The assumption the feedstock gas will be sourced in British Columbia is unqualified and speculative. The KMMEF SEPA Final Environmental Statement 7.3.2 states, “At this time, NWIW has not entered into contracts for the supply of natural gas to the proposed project.” There has been no report this has changed.

The cascade of errors in upstream emissions continues by using the GHGenius modeling tool for life cycle analysis with questionable results.

As noted on SSEIS p. 40, “In the First SEIS, the GHGenius model was used to estimate upstream emissions for natural gas from BC (S&T Squared 2013). The GREET model was used to provide estimates for the U.S. Rocky Mountain natural gas source (ANL 2017).”

The GHGenius model used in the first GHG analysis is outdated (highly revised edition 5.0 released in April 2018) and apparently does not provide the same output data for transmission emissions as the GREET model. This is apparent in comparing the transmission emissions for the BC gas source and the WY source.

Table A-2 Low Emissions Scenario in Appendix A compares the emissions data from the GHGenius model for BC gas with the GREET data for North American gas. It uses GHGenius data from the first GHG analysis. While the data is like that presented in the first analysis, some categories have been combined which blurs the source of some of the emissions, particularly those from pipeline transmission. Transmission emissions, fugitive and storage, appear to be almost three times the value given for BC transmission emissions.

The KMMEF SEPA Final Environmental Impact statement provided a description of factors in determining upstream emissions. “Natural gas extraction involves the operation of compressors and separation equipment at the wellhead and gas processing facilities. Figure 3-8 shows the upstream emissions pathways for natural gas. GHG emissions are calculated based on the energy inputs from aggregate data, which are inputs to the GHGenius and GREET models. The models calculate the life-cycle emissions, including the upstream emissions, to produce fuels for gas extraction and processing. The GREET model also calculates energy inputs and emissions from compressors used for natural gas transport and includes provisions for fugitive methane emissions at all stages of the extraction and

transportation processes. These models do not include emissions associated with the preproduction

phases of the upstream emissions (natural gas well development) and emissions from this phase are not included in the calculations as no well development is attributable to the proposed project.”  FSEIS 3-17 [emphasis added]

 

By omission, this statement implies the GHGenius model may not include all the emission factors included in the GREET model, which could explain the greater emission rate yielded by the GREET model for North American gas.

Emissions from pipeline transmission in the GHGenius model for BC gas are insufficiently calculated, producing an inaccurate emission rate for upstream emissions. As previously noted, the pipeline transmission distance from Kalama to the BC gas source is incorrect. Pipeline distance matters in determining emissions. As stated in Appendix A of the SEIS, KMMEF Supplemental GHG Analysis, 2018, p. 29, Natural Gas Transport- “Natural gas fueled compressor engines compress and move gas along the pipeline network…Natural gas flows through a pipeline at constant pressure and the pressure drops as gas is removed from the pipeline and due to pipe friction. As more gas is moved through the pipeline, additional compression energy would be required to move the gas, which is part of the upstream analysis.” [emphasis added] Additional compressors needed on longer pipeline routes require more energy and increase fugitive emissions.

I will emphasize this point by quoting the late William Brake, a retired chemical engineer and registered professional engineer with a 35-year career in the natural gas business.

“The Chapter 4 Air Quality and GHG discuss at length the reasons why GHG emissions are not included for the natural gas transmission of the feedstock to the Kalama Methanol Refinery.  The reasons and thought processes are flawed and the flow of natural gas either from the north or from the south requires compression to move the gas along the pipeline. The incremental 320,000 MCFD natural gas required for this facility is a significant amount of gas on the entire transmission system and it requires horsepower to move the gas and incremental horsepower is emissions and GHG. It appears this subject is too challenging to admit that there is significant GHG related to Natural Gas Transmission and is avoided by “Wordsmithing” the revised Chapter 4.  This is unacceptable. http://kalamamfgfacilitysepa.com/wp-content/uploads/2016/09/FEIS-4-0-Air-Quality_GHG.pdf The No Action Alternate is recommended for this project.” William Brake, Formal comment #18 on FEIS, 2016 October 19

This raises doubt about the reliability of the GHG emission rate produced in the first GHG analysis and used again without correction in this second analysis.

In the first GHG analysis the upstream emission rate of 0.71% calculated 0.2848 tonnes CO2e per tonne methanol for BC gas feedstock and 0.3403 tonnes CO2e for North American gas, and possibly more. The baseline and market mediated rate were determined to be 0.289 tonnes CO2e/tonne methanol.

I believe these numbers are unreliable and low-balled. However, these numbers are brought into the second supplemental EIS uncorrected where they create a cascade of dubious conclusions. The 0.71% emission rate and 0.288 tonnes CO2e/tonne methanol are now considered 2nd SEIS low values. (SEPA 2nd SEIS, Sept 2020, p. 82) An upstream methane emission rate of 0.97 percent and 0.333 tonnes CO2e/tonne methanol, or the middle value, is considered more plausible. SSEIS, p. 80. This is the emission rate the EPA Shale GREET model produced for North American gas, Table A-3 Medium Emissions Scenario SSEIS.

While the plausible upstream emission rate is 0.97 percent, the analysis of alternate pathways for methanol imports to China sets KMMEF upstream emission rate at the low and questionable 0.71 percent. See Table A-7 where the GHG emission from upstream is set at 0.289 tonnes CO2e/T methanol, corresponding to the 0.71 percent emission rate. To further skew this input in KMMEF’s favor, this same value is assigned to all other reviewed methanol producers.

The reasoning given is, “A key distinction in how the ESM handles emissions from this pathway compared to China-based natural gas methanol, is that upstream emissions related to natural gas extraction and processing is set equal to that of KMMEF. This assumption was made based on the lack of emissions data from the methanol exporters evaluated in this study and the uncertainty around upstream methane emissions from natural gas extraction and processing (Gan et al. 2020).” SSEIS, p. 62. [emphasis added]

Incongruously this statement follows the statement in the previous paragraph that, “The difference in life cycle GHG emissions is mostly due to upstream natural gas emission rates and the difference between KMMEF’s ULE technology and the combined reforming technology used by some of the 29 existing facilities. To a lesser degree the emissions difference is attributed to electricity and transportation emissions. The lifecycle GHG emissions of imported methanol may decrease over time as new facilities come on-line using ULE technology or even newer processes.”

Table A-7 compares other global producers to KMMEF using the same implausible upstream emission rate despite acknowledging much of the difference in life cycle emissions is due to upstream emissions. The low upstream emission rate attributed to KMMEF British Columbia gas feedstock compared to other producers seems more unrealistic considering BC gas will be transported and emitting along almost a thousand miles of pipeline compared to methanol producers on the Persian Gulf in Iran sited less than 100 miles from petroleum reserves ranking in the top five globally.

Further analysis based on data with such inaccuracies and unjustified assumptions on upstream gas emissions would seem an exercise in futility.

KMMEFF should be denied permits based on the multiple verifiable analyses the refinery will produce millions of tonnes of greenhouse gases in Washington.

3. The 786,117 MT CO2e estimate of in state emissions is misleading and without validity.

In reviewing 3.7 Significant impacts and mitigation, p. 105, there is the statement, “GHG emissions occurring within Washington State from the sources listed above are estimated to be between 786,117 and 1,421,748 MT CO2e per year.” This range of in state GHG emissions is patently incorrect.

For onsite process emissions alone, current air discharge permit, ADP 16-3204, issued by Southwest Clean Air Agency June 2017, states on p. 3,

“2.1 Emission Limits

No. 1 Combined greenhouse gas emissions from approved emission units shall not exceed

1,076,000 tons of C02e per calendar year. Annual emissions shall be calculated using

procedures consistent with the provisions of 40 CFR 98.”

In metric units this is equal to 976,131 metric tons of CO2e. This would be a very minimum NWIW Kalama methanol refinery would emit annually. The technical support document, p. 18, states the facility-wide potential to emit is 1,119,890 tons per year (1,015,947 metric tons). The permit states NWIW agreed to a voluntary limit of less than potential capacity to emit.

The range for in state emissions should begin at no less than 1 million metric tons annually. This alone is a significant increase in Washington state emissions. Adding other in state emissions, including over 250,000 metric tons annually for power purchases, would make KMMEF Kalama methanol refinery one of the top three GHG emitters in the state, excluding TransAlta. Note, this makes data in SSEIS Figure 3-1 also invalid.

When the stated legislative goal in Washington state is to reduce current GHG emissions, there is no rational environmental reasoning to allow shoreline permits for KMMEF Kalama methanol refinery.

4.  Can even 1 million metric tons of CO2e be verifiably mitigated?

From information in the air discharge permit this refinery has the capacity to emit over 1 million metric tons of GHGs every year just on the process site.

NWIW states they will mitigate all in-state emissions. Priority will be given to projects in Cowlitz County. PLEASE - require specific examples of mitigation projects and their verifiable ability to remove greenhouse gases from the atmosphere.

The only viable way to remove CO2 from the atmosphere that I am aware of is by growing trees or crops. According to the EPA greenhouse gas calculator it would take 1,306,000 acres of average forest land to remove 1 million tons of GHG in a year.

Cowlitz may be a large county but it only comprises about 746,000 acres. There is no way on God’s green earth NWIW will be able to mitigate a fraction of its total emissions in projects in Cowlitz County or all of Southwest Washington.

Demand accountability for a realistic mitigation plan now because you surely will not get voluntary compliance later. Do not let NWIW be one more company that tries to buy its way out of fouling our environment and turns up the heat on climate change.

Deny shoreline permits for NWIW.

 

5.  Greenhouse gas emissions from KMMEF marine dock operations are not examined in the DSSEIS and need to be evaluated and added to total project emissions.

The KMMEF marine dock is integral to this refinery project, otherwise we could just refer to it as the NWIW refinery project. However, GHG emissions, from dock operations have not been examined in this draft SSEIS or in the first supplemental environmental impact statement.

The first SEIS simply deferred discussion of marine dock GHGs, different from methanol vessel transport or process emissions, to what was included in the FEIS.

The FEIS states-

“The proposed marine terminal would accommodate the oceangoing vessels that would transport

methanol to destination ports. It would also be designed to accommodate other vessel types and,

when not in use for loading methanol, would be made available for use as a lay berth where

vessels could moor while waiting to use other Port berths or for other purposes.” 2.1

 

“The proposed project also incorporates the use of shore power for the marine terminal. Shore

power allows ships to “plug into” electrical power sources on shore. Turning off ship auxiliary

engines at berth would reduce ship diesel emissions and result in GHG emission reductions,

depending on the source of electric power from the grid. GHG emission reductions from shore power have not been calculated for the proposed project, but studies completed in other locations show reductions of from 25 percent to 50 percent (EPA 2017).“  p. 3-35&36

 

“Marine Terminal Alternatives

The Marine Terminal Alternatives would both result in the same potential impacts to energy

and natural resources and are assessed together.

Both Marine Terminal Alternatives would generate demand for electricity for lighting, loading

equipment, and the operations shack and dockworker shelter. They would also generate

demand for electricity from the use of shore power (also known as “cold-ironing”). Both

Marine Terminal Alternative would generate a peak electrical demand of approximately 3 megawatts (accounting for both methanol loading activities and the use of shore power by vessels serving the methanol manufacturing facility and lay berth vessels), and an estimated annual electricity use of approximately 11,000 megawatt-hours based on preliminary engineering estimates. This electricity demand would be negligible compared to the approximately 5 million megawatt-hours of energy sales by the Cowlitz PUD in 2013.

Therefore, the operation of the Marine Terminal Alternatives would not result in significant adverse impacts to energy and natural resources.” P. 7-7 & 8


In the analysis of purchased power only power associated with methanol process is examined, not that from shore power required by vessels at berth, estimated to be 72 visits from Panamax methanol tankers and up to 12 other vessels using the dock as lay berth per year. (I will note this area of the river recently acquired additional stern buoys, meaning additional vessels under their own power awaiting berth will be emitting GHGs and air pollutants in the region.)

Looking just at shore power (aka cold-ironing or shore to ship power) use from vessels at berth, the preliminary estimate of 11,000 MW hours annually is likely lowballed. Per EPA GHG calculator this low amount of electricity generates 7,777 metric tons of CO2e. This is more than other GHG emitting activities analyzed in both SEISs.

The peak electrical demand of about 3 megawatts is also of dubious credibility. The first shore power installed at a terminal for tankers in 2009 at Port of Long Beach had a capacity of 8 MW.

“What is claimed to be the world’s first oil tanker terminal equipped with shore power to eliminate air emissions from berthed vessels was unveiled this week.

Pier T at the Port of Long Beach, used by BP America affiliate Alaska Tanker Co, has been equipped with a BP shore power installation, which can deliver up to 8 MW at 6,660 v.” http://www.tankeroperator.com/news/first-tanker-cold-ironing-facility-opened/1231.aspx

The Port of Boston commissioned a study to evaluate shore power requirements for various vessels and found power demands ranging from 3.36 MW to 13 MW.

“One Container vessel requires as much power as the largest Logan Airport Terminal (3.36 Megawatts).

Significant peak power demand on electrical grid. Just one cruise ship (Queen Mary 2) requires electrical demand equal to all required power to service all Logan Airport Terminals (13 Megawatts).”

Massport Shore-to-Ship Power Study August 5, 2016

https://globalmaritimehub.com/wp-content/uploads/attach_770.pdf

More recently the California Air Resources Board is determining regulations for emissions from ocean-going vessels at berth. In a lengthy report the following was stated about tanker vessels, “On average, a tanker’s auxiliary boiler can require one to several thousand kW of power during pumping operations, while auxiliary power load consumption for regular hotelling operations generally ranges between 700 kW to 1,000 kW per hour (Appendix H). Hotelling times for tankers transporting crude oil range between 5 to 173 hours per visit I-29 5. and the average berthing time for a product tanker is around 48 hours.” p.  I-29,  State of California AIR RESOURCES BOARD PUBLIC HEARING TO CONSIDER THE PROPOSED CONTROL MEASURE FOR OCEAN-GOING VESSELS AT BERTH STAFF REPORT: INITIAL STATEMENT OF REASONS DATE OF RELEASE: OCTOBER 15, 2019 SCHEDULED FOR CONSIDERATION: DECEMBER 5, 2019

https://ww3.arb.ca.gov/regact/2019/ogvatberth2019/isor.pdf

I strongly urge you to review the above CARB report. California is suggesting stricter regulation of vessel emissions at berth from ports with more than 20 ocean-going vessel calls per year.

‘CARB staff’s proposal to further reduce emissions from ocean-going vessels would require emissions control requirements at any port or independent marine terminal exceeding a specific visit activity threshold. If a port or marine terminal surpasses the 20 visit threshold, they must submit a plan to CARB by the end of the following calendar year describing how they will control emissions from the vessel activity at their facility.’’ P. ES-15

This one new Kalama dock would receive four times the vessel traffic under the California regulation requiring stronger emission controls.

The FEIS statement the Marine Terminal Alternatives are not significantly impactful is false.

Please rectify the serious omission of greenhouse gas analysis from vessels at berth at the proposed KMMEF marine dock in the second supplemental EIS.

6.  The data on purchased power is incorrect and based on speculative assumptions.

Purchased power is detailed in Appendix C of the SSEIS and includes the following:

Purchased power

The proposed project will import 100 MW (864,000 MWh) of electric power from the regional power market through the Cowlitz PUD transmission system during continuous operation. Power demand is reflected in Megawatt Hours (MWh). Total power demand is shown in Table C-17 for the ULE Alternative. Power demand over the 100 MW provided by purchased power is provided for by the on-site natural gas combustion turbines (emissions from the on-site power generation are captured in the ULE Production Scenarios).  P. C-20

Electrical power demand

Electrical power will be required for KMMEF operations. A portion of the power required will be generated from onsite combustion turbines, and the rest, estimated to be 100 MW by NWIW, will be purchased from the power market. Emissions from electrical generation by the onsite combustion turbines are included in the emission calculations for methanol production for the ULE alternative. Emissions for the 100 MW of purchased power are based on three generation scenarios:

• Low Scenario. All purchased power is generated from renewable sources. The current renewable mix from Cowlitz PUD is 86% hydroelectric, 8% nuclear, and 6% wind.

• Mid Scenario. Purchased power is from a mix of generation sources, which changes over time in line with the expected, future energy mix in accordance with the Washington State Clean Energy Transformation Act (CETA) signed into law on May 7, 2019. In the mid scenario, generation from 2020 to 2030 is from the current marginal power source (defined as the source of electricity that is first or cheapest available to meet an increased power demand), generation from 2030 to 2045 is from a mix of 20% marginal power and 80% renewable power, and generation from 2045 and beyond is all from renewable sources.

• High Scenario. Purchased power is all from the current marginal power source.

A NW Power and Conservation Council study of CO2 emissions in the NW power system published in 2018 concluded that the expected emissions over the time frame of the project from marginal power sources were in a range that correlates well with the emissions from a combined cycle natural gas-fired powerplant. Therefore, for the purposes of this study, a combined cycle natural gas-fired powerplant was assumed as the current marginal power source.

Emission factors for combined cycle natural gas-fired powerplants, hydroelectric generation stations, nuclear powerplants, and wind turbines were derived from GREET and are shown below in Table C-1.”  SSEIS p. C-3

Table C-1 shows range of emissions from power purchases from low to high scenarios. [extracted data]

Purchased Power GHG Emission Factors (g/kwh)

CO2e     0.61       216.57    431.43

The 864,000 MWh from 100 MW demand for continuous operation is incorrect. Multiplying 24 hours of 100 MW demand for 365 days yields 876,000 MWh.

As noted in a previous comment, nowhere in the SSEIS are the electrical power requirements and sources for operating the KMMEF marine dock, including shore power provided to over 80 vessels at berth annually, evaluated. The GHGs generated from this power and marine dock vessel operation are not evaluated.

Based on scenario descriptions above, GHG emissions from on-site purchased power range from 526.7 for low estimate, 187,112 mid estimate, to 372,752 MT CO2e/year for high estimate per Table 3.5-2.

So which of the electrical power resource scenarios and resulting GHG emissions are most likely and reasonable?

All the estimates are low given the absence of including KMMEF dock operations and error in calculating the hours of operation in a year.

The low estimate is unlikely given a large new industrial load will not be allowed as a priority customer for Cowlitz PUD’s hydropower resources. Current policy dictates NWIW will be required to purchase power from the open market.

The mid estimate is speculative based on the ability of current electrical power resources to move towards clean and renewable resources. [It is also speculative dirtier generation from coal will be replaced by arguably cleaner gas generated electricity given the huge amount of gas NWIW will be sucking out of the limited PNW gas infrastructure.] It is speculative and dubious NWIW will even be operating at the farthest time frame that includes the cleanest power.

The high scenario, with estimate of 372,752 MT CO2e/year by using current marginal resources, is the most likely and reasonable number to work with.

To put the high scenario GHG emission number in larger context, the EPA GHG calculator states 876,000,000 kWh of electricity produces 619,367 metric tons of CO2e.

Refining the power resource further, the following is the result from 2018 eGRID data for the same amount of electricity:

“Using the eGRID subregion NWPP (WECC Northwest) emission rates and 4.80% percent line loss, your estimated annual use of 876,000,000 kWh of electricity results in 586,632,672 pounds CO2, 367,219 pounds SO2, and 550,829 pounds NOX emitted in one year from the power plants in your area.

It would take 6,896,152 seedlings grown for 10 years or 313,053 acres of forests in one year to offset those CO2 emissions.”

https://www.epa.gov/egrid/power-profiler#/NWPP

Converting the above to metric tons, the CO2 alone represents about 262,000 metric tons of GHG. Nitrous oxide has 298 time the global warming potential of CO2. https://climatechangeconnection.org/emissions/co2-equivalents/

Even the estimate of GHGs from purchased electrical power for on-site consumption in the high scenario is lowballed. Please redo the purchased power calculations and emissions to reflect reality.


7.  What is a reasonable answer to the basic question, how much CO2e will be produced in refining 3.6 million metric tons of methanol per year?

When science looks at a question and comes up with an answer the usual first response to the answer should be another question.  Is the answer reasonable? In the case of NWIW the answer is no.

Looking only at methanol process, from Table 3.5-2 GHG Emissions from On-site Sources, the ULE process and purchased power (the 100 MW demand required for the process) will produce GHG emissions ranging from the low estimate 728,535.7, to mid estimate 915,121, to the high estimate 1,347,803 MT CO2e/year.

The high estimate means 0.374 metric ton of GHG would be emitted for every metric ton of methanol produced. The low estimate yields 0.202 metric ton GHG per ton of methanol.

The methanol industry would likely find these answers ludicrously implausible.

“Ten or more years ago, a typical methanol manufacturing plant would emit about 0.9—1.0 metric tonnes of carbon dioxide for every ton of methanol produced. In addition to the environmental concerns, large CO2 emissions represent operational inefficiencies in a methanol plant, since the carbon emitted as CO2 is not available for making methanol molecules. In fact, excess CO2 from other industrial facilities can also be captured and consumed to increase methanol production. Through the implementation of efficiency improvements and through replacing of older facilities with newer plants that use more efficient technologies, over the last decade methanol plants have been able to significantly reduce CO2 emissions by up to 40%. Some facilities report emissions as low as 0.54 tonnes of CO2 / tonne of methanol produced.  This is equivalent to emitting 3.8 lbs of CO2 per gallon of methanol.” https://methanolfuels.org/about-methanol/environment/

The ULE process is not new. It is based on a small prototype, the Coogee facility in Australia, operational more than twenty years ago.

Here is what I told Southwest Clean Air Agency about the Coogee ULE process in my comments January 2019 regarding extension of NWIW Kalama’s air discharge permit.

“The ULE process is not a conventional methanol process with conventional equipment and has only been used in one small facility that has since been closed, the Coogee Methanol Plant, Laverton North, Victoria, Australia, operated by Coogee Energy Pty Ltd.

https://insider.thewest.com.au/august-2017/power-played/

The best information on the Laverton Coogee methanol process and emissions can be found in Coogee Energy Pty Ltd Methanol Plant Environment Improvement Plan, December 2003. Attached. http://s3.amazonaws.com/zanran_storage/www.coogee.com.au/ContentPages/1245343343.pdf

This was the plant’s third improvement plan (EIP). They had problems. They admitted it was an experimental process that needed improvement.

“The Coogee Methanol Plant is Australia’s only methanol production facility, and is currently capable of producing between 70,000 to 80,000 tonnes per annum of chemical grade methanol. The plant operates 24 hours a day, 7 days a week, all year round.” EIP p. 10 The Coogee methanol plant had capacity to produce in one year what NWIW Kalama plans to produce in 8 days. In other words, the NWIW production capacity is proposed to be about 45 times greater than the prototype on which it is designed.

In 2003 the Coogee plant had been operating almost ten years. Their aim was to produce methanol with greater efficiency and less CO2e emissions. The EIP states in 2002 that 0.781 Tonnes CO2e were produced per tonne of methanol, EIP p. 21. If this emission rate were applied to NWIW Kalama production of 3.6 million tons methanol per year, then NWIW would be emitting 2,811,600 tons of CO2e annually at the refinery site alone, over twice the estimate projected in the ADP.”

When scientific inquiry reveals extraordinary results, extraordinary proof is required. The unrealistically low emissions Northwest Innovation Works claims will result from their ULE methanol process demands extraordinary proof. Chemical equations describing a perfect process are not sufficient or realistic.

Demand real world examples the NWIW ULE process will produce the extremely low emissions as claimed on a large industrial scale.

8.  Why does this SSEIS devote about two-thirds of the intended greenhouse gas analysis on an economic study, and poorly done at that?

“Economic Analysis: A market-based evaluation was conducted to assess whether methanol produced by the project would substitute for or replace other sources of methanol, rather than supplement them.” SSEIS p. 38

According to Washington law and Department of Ecology website the purpose of SEPA and environmental impact statements is to identify and analyze environmental impacts. This begs the question why more consideration was not given to identified GHG emissions. Fugitive and transportation emissions from a long pipeline route are not analyzed. Emissions from operation of the KMMEF marine dock are ignored. There is no substantiation of low emission claims from the ULE process itself, despite the ULE process being untested on a huge industrial scale and results from the Coogee ULE facility contradicting such low emission claims.

Yet this SSEIS goes into mind boggling detail, or perhaps obfuscation, to guess what methanol markets will look like in forty years to support a result intended to make Kalama methanol look like the cleanest and most competitive methanol on the planet.

The most obvious economic question might be, if NWIW’s ULE methanol process is so wonderful then why aren’t other methanol producers replicating it? Especially the big players in the market, like Methanex? After all, the technology has been around for more than twenty years. If no one else is using it, the logical course would be to find out why not? Could it be the most forward-thinking methanol producers are moving to LCM, low carbon methanol, and fossil free renewable gas feedstock?

Why does the economic analysis not mention NWIW’s parent company GTM’s intentions to produce methanol in British Columbia, closer to gas feedstock producers?

Financial advisors have a fiduciary responsibility to advise that past performance is no indication of future returns when it comes to investment risk. Yet this SSEIS seems to have no doubt about the reliability of their future assumptions in drawing a conclusion.

Indeed, there is not even past performance when it comes to Northwest Innovation Works. It is a paper LLC created in January 2014 to pursue a speculative venture. A major investor, British Petroleum, pulled out within a year after the price of oil dropped precipitously making the economic viability of the venture too risky. The principals have no credible background in petrochemicals. President Vee Godley was previously involved in the failed Hoku silicon plant in Idaho.

While supporters complain vociferously about the lengthy permit process, NWIW has never produced complete financial and facility plans. They have claimed much, yet never revealed the project would be the world’s largest methanol refinery. One would think this might be a selling point for a worthy project.

The original idea was to use the CR process and not more than 36 MW demand from the power grid. This got changed when they realized the air pollution controls from burning so much natural gas for power generation was too costly.

Then there was the issue of wastewater disposal and impingement on shorelines and wetlands.

When they were caught hawking the project to investors as producing methanol for fuel instead of the stated purpose as plastic feedstock, they needed another port lease amendment.

NWIW is promoted as producing taxes and jobs. Yet the port agreement only requires 80 permanent jobs, less than one job per acre of waterfront industrial property. NWIW has lobbied the legislature for tax benefits. The project has applied numerous times for federal tax dollars to build the dock. It has applied for a two-billion-dollar federal loan to build the refinery.

The tax benefits and two billion loan should be considered in the SSEIS economic analysis considering the implications such subsidies might have on relationships with global trading partners, if the state subsidies to Boeing are any indication.

After more than six years of experience with Northwest Innovation Works, please heave this project overboard. It is a risky financial investment and a sure route to environmental and climate degradation.

Thank you for pursuing environmental truth and providing decision makers with the best most credible information we can obtain in these trying times. The health of Washingtonians and a high-quality environment that sustains us depend on your efforts.

 

Diane L. Dick

13 Saint Helens Lane

Longview, WA  98632
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Comment From: Columbia Riverkeeper (Kate Murphy)

10/08/20 @ 5:00 PM
Hello, 

Please find attached our song about Kalama, which we would like to include as an official comment for the Kalama DSEIS. 


Thank ...↓

Sincerely,
Kate Murphy
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Comment From: Kimberly Kramer

10/08/20 @ 5:00 PM
Attachments:

Comment From: Rayna Holtz

10/08/20 @ 5:00 PM
Attachments:

Comment From: Kate Murphy

10/08/20 @ 5:00 PM
Comment on Kalama Methanol DSEIS
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Comment From: Thomas Gordon

10/08/20 @ 4:59 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 1,100GW. 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 projects.
China's economic system is based on abundant and cheap capital being made available to the state-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 50 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 pollution.
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.
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Comment From: Richard Voget

10/08/20 @ 4:42 PM
The SSEIS shows clearly that the facility would generate around 4.6 million tons of carbon dioxide pollution each year, equivalent to around 5 percent of the state's total climate emissions. This much is clearly established and irrefutable. The missi...↓
The entire premise of the Kalama project is establishing 40 more years of consumer demand for gas rather than moving away from fossil fuels. How can you confidently predict consumer demand for the next 40 years? Coal production has crashed as the price of natural gas became cheaper due to fracking. I have included the Chart of the Week from the April 2019 World Economic Outlook that shows prices dropped 76 percent for solar panels and 34 percent for turbines between 2009 and 2017 making them competitive alternatives to fossil fuels and more traditional low-carbon energy sources such as hydropower and nuclear. Renewable energy generated electricity will become cheaper than methanol and all the other fossil fuels in the not to distant future and well within the 40-year premise of the SSEIS. The price of methanol will not remain constant as predicted in the report. The Kalama refinery will eventually close as methanol becomes noncompetitive.
Please do not approve this project that will contribute to global warming until it closes due to market economics that were not evaluated in the report.

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Comment From: Sally Keely

10/08/20 @ 3:30 PM
KMMEF is a 3-part project: the lateral pipeline, the dock, and the refinery itself. They are all tied together. One is not able to operate without the other two. Either all three should be permitted or NONE should be permitted. (I favour the latter!)...↓
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Comment From: Kathy Boylan

10/08/20 @ 3:01 PM
No to Kalama methanol refinery. In these dire times it is time to stop listening to the petro chemical industry spin and consider the human and environmental costs of this highly toxic project. ENOUGH
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Comment From: evan johnson

10/08/20 @ 2:50 PM
No Kalama Methanol refinery. this project would cause a huge amount of climate pollution
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Comment From: Diane Dick

10/08/20 @ 2:44 PM
2020 10 08 Comment #8

Washington State Department of Ecology
Olympia, Washington
Re: Formal Comments on Kalama Manufacturing and Marine Export Facility Draft Second Supplemental Environmental Impact Statement, September 2020

Please deny Kalama Manufact...↓

Why does this SSEIS devote about two-thirds of the intended greenhouse gas analysis on an economic study, and poorly done at that?

"Economic Analysis: A market-based evaluation was conducted to assess whether methanol produced by the project would substitute for or replace other sources of methanol, rather than supplement them." SSEIS p. 38

According to Washington law and Department of Ecology website the purpose of SEPA and environmental impact statements is to identify and analyze environmental impacts. This begs the question why more consideration was not given to identified GHG emissions. Fugitive and transportation emissions from a long pipeline route are not analyzed. Emissions from operation of the KMMEF marine dock are ignored. There is no substantiation of low emission claims from the ULE process itself, despite the ULE process being untested on a huge industrial scale and results from the Coogee ULE facility contradicting such low emission claims.

Yet this SSEIS goes into mind boggling detail, or perhaps obfuscation, to guess what methanol markets will look like in forty years to support a result intended to make Kalama methanol look like the cleanest and most competitive methanol on the planet.

The most obvious economic question might be, if NWIW's ULE methanol process is so wonderful then why aren't other methanol producers replicating it? Especially the big players in the market, like Methanex? After all, the technology has been around for more than twenty years. If no one else is using it, the logical course would be to find out why not? Could it be the most forward-thinking methanol producers are moving to LCM, low carbon methanol, and fossil free renewable gas feedstock?

Why does the economic analysis not mention NWIW's parent company GTM's intentions to produce methanol in British Columbia, closer to gas feedstock producers?

Financial advisors have a fiduciary responsibility to advise that past performance is no indication of future returns when it comes to investment risk. Yet this SSEIS seems to have no doubt about the reliability of their future assumptions in drawing a conclusion.

Indeed, there is not even past performance when it comes to Northwest Innovation Works. It is a paper LLC created in January 2014 to pursue a speculative venture. A major investor, British Petroleum, pulled out within a year after the price of oil dropped precipitously making the economic viability of the venture too risky. The principals have no credible background in petrochemicals. President Vee Godley was previously involved in the failed Hoku silicon plant in Idaho.

While supporters complain vociferously about the lengthy permit process, NWIW has never produced complete financial and facility plans. They have claimed much, yet never revealed the project would be the world's largest methanol refinery. One would think this might be a selling point for a worthy project.
The original idea was to use the CR process and not more than 36 MW demand from the power grid. This got changed when they realized the air pollution controls from burning so much natural gas for power generation was too costly.

Then there was the issue of wastewater disposal and impingement on shorelines and wetlands.

When they were caught hawking the project to investors as producing methanol for fuel instead of the stated purpose as plastic feedstock, they needed another port lease amendment.

NWIW was promoted as producing taxes and jobs. Yet the port agreement only requires 80 permanent jobs, less than one job per acre of waterfront industrial property. NWIW has lobbied the legislature for tax benefits. The project has applied numerous times for federal tax dollars to build the dock. It has applied for a two-billion-dollar federal loan to build the refinery.

The tax benefits and two billion loan should be considered in the SSEIS economic analysis considering the implications such subsidies might have on relationships with global trading partners, if the state subsidies to Boeing are any indication.

After more than six years of experience with Northwest Innovation Works, please heave this project overboard. It is a risky financial investment and a sure route to environmental and climate degradation.

Thank you,

Diane L. Dick
Longview

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Comment From: RAYNA HOLTZ

10/08/20 @ 2:35 PM
Comment on the Second Supplemental EIS for the Proposed NWIW Kalama Methanol Plant rev. Oct. 8, 2020�from Rayna Holtz

My comments fall into two categories. First I look at the issue of greenhouse gas emissions that this study so wonderfully examined...↓

A. The depth and breadth of this SSEIS is impressive, as is the broad range of possibilities it must contend with. However, it suffers from errors, omissions, assumptions.
1. One unknown is how the methanol will be used. We do know that Northwest Innovation Works (NWIW), which is Chinese backed, told the Port of Kalama that the Kalama plant would primarily sell its methanol to markets for olefins in Asia, but when presenting the project to potential funders it emphasized profits from selling the methanol for use as fuel. This behavior does not inspire confidence, but does warn that NWIW will manipulate to achieve a for-profit goal rather than speak out of a confirmed set of ethical guidelines incorporated into the operations of its business. (Why then should we assume that NWIW will follow through with its promised voluntary mitigation plan?)

2. To account for the uncertainty about intended uses, the range of models in the SSEIS includes both use as fuel and MTO (methanol to olefins), but looking at Fig 3.5.3 on p.65 we see that the Chinese use of methanol for fuel quintupled from 2006 to 2016 and it continues to rise. Isn't it likely then that the use of fuel will overtake the use for olefins? Beyond this example the number and combination of variables far exceeds the capability of meaningful modeling. While we do not know precisely what the methanol will be used for, we do know that it will add GHGs to our overtaxed atmosphere starting in just a couple of years and continuing for 40 years (the projected life of the plant), including the next two decades when we it is critical that we reduce GHGs. What is not burned as fuel, will become a problem to the environment when it is discarded, since the uses for products derived from olefins do not break down and return to the soil, so they will present other problems.

3. It is simplistic to want to partially justify the permitting of a facility that uses fossil fuels, emits GHGs in bringing its raw materials to its site, emits more in producing its product, and still more while conveying its product to Asia merely because it produces just slightly fewer emissions than other producers of its product!!

4. This report is based on outdated science. It uses IPCC4 100-year GWP values to calculate CO2e, despite the fact that the IPCC subsequently updated them to more accurately reflect the significantly enormous GWP of methane in its first 20 years. On p. 90 this report even acknowledges that: "GWP values are periodically updated to reflect current science regarding the energy properties of GHGs and their lifetimes in the atmosphere." Thus the report should have used the most accurate and current GWP values, which are found in the IPCC's fifth Assessment Report's 20-year GWP. The reason given by the authors for using the IPCC4 100-year GWP is that they are "the most commonly used GWP values," meaning they have been around longest?!! This error biases all the results apparently deliberately so as to minimize the GWP of all the methane emissions. It doesn't matter what the annual GWP will be, averaged over the next 100 years! It matters tremendously what it is going to be annually between now and 2040!!

5. The calculations of upstream emissions are not well presented in this report, but seem to minimize the problem of methane escape at extraction sites, where gas is fracked. Researcher Robert Howarth notes that "scientists have measured big increases in the amount of methane, the powerful global warming gas, entering the atmosphere over the last decade." The evidence: "The chemical signature of methane released from fracking is found in the atmosphere, pointing to shale gas operations as the culprit." Howarth points to the fact that methane is most active in its first 20 years as having rapid rewards for curtailing its emissions: "Carbon dioxide emitted today will influence the climate for centuries to come, as the climate responds slowly to decreasing amounts of the gas. Unlike its slow response to carbon dioxide, the atmosphere responds quickly to changes in methane emissions. Reducing methane now can provide an instant way to slow global warming and meet the United Nations' target of keeping the planet well below a 2-degree Celsius average rise," Howarth said. (Robert Howarth, ecologist at Cornell University and author of the study published Aug 14 in the journal Biogeosciences.)
6. The problem of emissions from pipeline leaks all along the way is not mentioned. Pipelines are made of lengths of pipe connected. Over time, joints fail, as surrounding earth is disturbed by a variety of impacts, including earthquakes. Not only does this likelihood add to our burden of greenhouse gases, it adds threats to the health and safety of communities and ecosystems due to contamination and fire hazard. (I well remember my daughter's story when she was a Western Washington University student of a local incident: "On June 10, 1999, a gasoline pipeline operated by Olympic Pipeline Company exploded in Bellingham, at Whatcom Falls Park." - Wikipedia)
7. As the Department of Ecology News Release of Sept. 2 states, "The project would increase greenhouse gas emissions within Washington State by almost one million metric tons of carbon dioxide equivalent a year." And because the report uses the AR4 100-year GWP (see point 4 above) this under-reports the CO2e for whatever portion of this happens to be methane, so we need to multiply that figure by 86. Not helpful, especially when our Washington legislature's 2009 goal, which was to bring our emissions down to 1990 levels by the end of 2020, has already failed completely, and instead our emissions have increased by about 8 percent!!! What part of NO MORE EMISSIONS do we not understand?

8. This report does not consider the possibility that yet cleaner processes may soon make the Kalama technology with its "ultra-low emissions" obsolete.
*One possibility is producing methanol from the carbon dioxide in the atmosphere! An example: "Carbon dioxide-to-methanol process improved by catalyst," Science Daily, June 28, 2018, Penn State.
*Another: "Harnessing light for a solar-powered chemical industry," by Associate Professor Daniel Gomez, Royal Melbourne Institute of Technology, published in ACS Applied Energy Materials, Jan. 30, 2019. In this second article Dr. Gomez states: "Chemical manufacturing is a power hungry industry because traditional catalytic processes require intensive heating and pressure to drive reactions." And, "The photo catalyst we've developed can catch 99% of light across the spectrum, and 100% of specific colours. It's scaleable and efficient technology that opens new opportunities for the use of solar power�moving from electricity generation to directly converting solar energy into valuable chemicals."

9. There is no mitigation that can adequately compensate for adding GHGs to earth's atmosphere at this time in history. Is it OK to add just a little oxygen to a raging house fire?

B. The context for this permitting process is not average. This is a precedent-setting moment, when every person and every life form on the planet is facing a crisis with a magnitude as great as the one that destroyed the dinosaurs. We simply cannot behave as though it's business as usual, and the best-written set of justifications and excuses wins a work-around to avoid the rules.
1. RCW70A says, under Intent�2020 c 79: "(3) The longer we delay in taking definitive action to reduce greenhouse gas emissions, the greater the threat posed by climate change to current and future generations, and the more costly it will be to protect and maintain our communities against the impacts of climate change. Unchecked, climate change will bring ever more drastic decline to the health and prosperity of future generations, particularly for the most vulnerable communities."
A new methanol plant in Washington would hinder the difficult task that is so urgent right now: to turn our GHG emissions around. With every passing month, more damage is done because of the effects of climate change, and some of the processes unleashed by global warming are actually accelerating its damage and speed (for example: the thawing of tundra is releasing additional methane that had been sequestered in the frozen tundra!) Climate change is increasing in momentum, so that some damages we can still hope to avert by reducing GHGs this year, will become inevitable if we wait to act until next year.

2. Until recently the United States has enjoyed one of the most stable democracies in the world, with time-honored institutions that enabled us to have the rule of law to protect our human rights and welfare. But we have not shouldered the responsibilities that come with our extensive privileges and wealth. According to the Center for Climate and Energy Solutions, the United States leads the world in Per Capita Greenhouse Gas Emissions, with over 18 tons of CO2 equivalent per person in 2017. Russia follows with a bit more than 15, then Japan with a bit less than 10, and the European Union is at about 8. The U.S. is responsible for 25% of the cumulative emissions of GHGs from 1751-2017, followed by the EU at about 22%. It's high time to step up. No simple for-profit venture, the possibility of initiating a successful new corporate enterprise, can take priority over this existential necessity.

3. Department of Ecology's Perry Lund states in his letter of October 9, 2019, to Dr. E. Elaine Placido, Cowlitz County, that "By law, Ecology must review all CUPs for compliance with the following: 1) The Shoreline Management Act (RCW 90.58)." Looking, therefore, at RCW 90.58.020, in "Legislative findings�State policy enunciated�Use preference", we find that the third paragraph lists "seven uses of state shorelines to guide the development of master programs for shorelines, "in the following order of preference which: (1) Recognize and protect the statewide interest over local interest; (2) Preserve the natural character of the shoreline; (3) Result in long term over short term benefit; (4) Protect the resources and ecology of the shoreline. . ."
Although a Kalama methanol plant may bring jobs and an economic boost to the local folks, the broader statewide interest will be better served with less GHGs and a healthier shoreline. The long term benefit will be much better served by NOT siting an enormous methanol plant where it can jeopardize "the resources and ecology of the shoreline."
This shoreline is part of the magnificent Columbia River estuary, whose health and water quality affect large communities of marine life both locally and downstream, extending to shorelines north and south along the Washington and Oregon coasts. Further, this ecosystem lies at a critical bottleneck for a majority of Washington's vital salmon runs, which travel from the Pacific Ocean back up the Columbia to numerous feeder rivers draining both the eastern Cascades and the western Rockies, spanning all of eastern Washington and part of British Columbia. These waters must be protected for the sake of innumerable beleaguered salmon stocks that have already been decimated by dams and premature melting of snowpack causing excessive warming of spawning streams that consequently cannot hold adequate oxygen to keep spawning salmon alive. On these salmon runs depend not only fisheries that have supported indigenous fishermen since time immemorial, and more recent commercial and recreational fisheries, but also the iconic Southern Resident Killer Whales of Puget Sound, now unable to find sufficient forage year-round to sustain healthy reproductive adults. It is unwise to allow any more dangers to further transform one of their key habitats into a gauntlet beset with hazards. (Further detail: see "Policy on Coastal Liquefied Natural Gas Facilities," attached.)
RCW 90.58.020 also states, "Uses shall be preferred which are consistent with control of pollution and prevention of damage to the natural environment, or are unique to or dependent upon use of the state's shoreline." There is no industrial plant that is immune to accidents. The siting of a large methanol facility in such a sensitive shoreline with the potential to cause lethal harm to so many already struggling species with both extremely high economic value and incomparable iconic northwest significance poses unacceptable risks of the sort this law warns against.

In summary, the backdrop of climate change against which this methanol plant is proposed dwarfs all other considerations with its multiple threats and exigencies. We must look at this decision with eyes wide open, and make a decision that will help slow the unraveling of the planetary systems on which biological life depends. Deny the conditional use permit.

Sincerely,
Rayna Holtz

Attachments:

Comment From: Mark Keely

10/08/20 @ 2:13 PM
There is uncertainty to rely on a narrow set of bottom up estimates for methane leakage rates while leaving out top down leakage rates. It is suspect to have one and not the other. Considering the multiple locations and long distances from the wells ...↓
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Comment From: eileen johnson

10/08/20 @ 2:07 PM
No kalama methanol refinery. It is an environmental disaster in the making that would poison the Columbia river and further polute the pacific NW air.
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Comment From: Bill Adams

10/08/20 @ 2:05 PM
Please reject this project. Despite what the proponents claim, it's a dirty project and will do nothing to combat global warming. It's estimated that it would emit 4.6 million tons of carbon pollution per year. That's a lot of dirty air and it would ...↓
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Comment From: Sally Keely

10/08/20 @ 2:01 PM
Ecology caught the shell company Northwest Innovation Works in yet another lie. On page 13 of the DSSEIS Ecology describes how the methanol produced in the Kalama Methanol Refinery could be burned as fuel, even 100% of it burned as fuel, despite the ...↓

As Ecology noted, once a tanker leaves dock, the product on board can be sold to anyone on the global market including wholesale commodity traders who could sell the methanol to other middlemen. Sale records would be impossible to track. Port has no way to enforce what the Chinese government does with the methanol or even if its destination is China.

The amendment says that NWIW will self-report any violations. But we know that NWIW is not credible, there have been so many lies. The Port and NWIW have a very cozy relationship. We rarely hear from NWIW, the Port Commissioners seem now to be NWIW's spokespersons.

In terms of the end use of the methanol, NWIW tells one thing to potential investors and another to the public and regulatory agencies. Reporting in April 2019, Oregon Public Broadcasting, our local PBS, caught NWIW in a major lie, telling investors the methanol is to be burned as transportation fuel while telling the public that it is to be used as an olefin for plastic production(2).

In summer 2017 NWIW sponsored an industry conference called "Sowing the Seeds of a Cleaner Future"(3) that focused on the prospects of using methanol as a liquid fuel, even going so far as calling it 'Liquid Sunshine'(4). The conference reading materials do not even mention plastic production.

Wu Lebin, the chairman of C.A.S. Holdings, has repeatedly said the end use of the methanol is for fuel including to Reuters in December 2017(5)(6) admitting a goal of the company is to "drive use of methanol as a transportation fuel for cars and ships." More recently, for an International Capital Conference last November(7), Mr. Lebin's bio says that NWIW will use the ULE process to convert North American gas to methanol to provide China with fuel.

It is avidly clear that with this amendment the Port is trying to sidestep the shorelines process, limit the scope of the cradle-to-grave GHG emissions in the FEIS, and mislead the public and state regulators. They are building this huge fracked-gas-to-methanol refinery, they've marketed the methanol as a fuel source, and now they are asking us to believe the methanol will never be burned. And note if it is burned as fuel, according to their own FSEIS (Appendix B, page 50), that would add an additional 5.44 million tons of carbon pollution annually. This dock use "promise" cannot substitute for the legal requirements of a full true SEPA analysis of GHG emissions including from burning NWIW's methanol as fuel. We are counting on Ecology for holding true to that science, not the speculation described in the DSSEIS.

Don't get me wrong. I vehemently oppose this project no matter the end use of the methanol because methane gas is too environmentally damaging, and our state should and can be a model to the nation in moving to clean renewable energies immediately. But NWIW and the Port of Kalama are trying to have it both ways, while lying to the public, state regulatory agencies, and the Dept. of Ecology.

DENY the shorelines permits.

1. http://opb-imgserve-production.s3-website-us-west-2.amazonaws.com/original/proposed_dock_usage_agreement_amendment_no_1.pdf
2. https://www.opb.org/news/article/methanol-plant-kalama-fossil-fuel-china/
3. https://nwinnovationworks.com/news/sowing-seeds-cleaner-future.html
4. https://ngi.stanford.edu/sites/default/files/20170731_Liquid_Sunshine_Pre-reading_material.pdf
5. https://www.reuters.com/article/us-china-usa-gas-methanol/chinas-cas-plans-gas-to-methanol-plant-on-u-s-west-coast-idUSKBN1DZ0BH
6. http://www.chinadaily.com.cn/business/2017-04/05/content_28793866.htm
http://www.internationalcapitalconference.com/speakers/wu-lebin

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Comment From: Barbara Bengtsson

10/08/20 @ 1:01 PM
The proposed Kalama Methanol Plant presents yet another false solution to the problems we are faced with in this pivotal time. A time marked by disasters, inequality, and a sense of uncertainty, if not doom. Wildfires and storms are increasing in sev...↓

The possibility of changing course, still exists. If we follow the recommendations of the IPCC and reduce emissions by about 50% in the next ten years, we can still prevent the earth's climate from completely spinning out of control. This is why the proposal to build a large methanol plant at the mouth of the Columbia River is utterly preposterous. Any project that relies on the continued extraction of carbon from the earth, where it is safely sequestered, sets us on a dangerous path to irreversible climate disaster.

But climate disaster is not the only threat exacerbated by continued fracking and drilling. If, as the proponents claim, the methanol produced by this plant would be shipped to Asia and used in plastic manufacturing, it would contribute to the ecological disaster caused by the rapacious use and discard of plastics. Today plastics are ubiquitous components of our environment. Most of us know about the "Great Pacific Garbage Patch," which turns out to be not so great for life in and around the oceans. Plastics are making their way into the stomachs of whales, fish, and birds. Not even remote islands are safe from their toxic reach. In the Pacific Ocean's Midway Atoll, an Albatross nursery, chicks are dying of plastic pieces unwittingly fed to them by their parents. Scientists are predicting that by 2050 there will be more plastic than fish in the world's oceans. Is this the earth we want to leave behind? If innovation were truly at the core of NW Innovation Work's business model, the company would work on developing more efficient, effective and sustainable processes for collecting and recycling the plastics currently in circulation instead of proposing to make more.

If the methanol would be used as fuel, it would worsen the climate crisis by contributing to greenhouse gas pollution and by delaying the adaptation of renewable energy sources. Data suggests that fracking operations are leaking much more methane than previously estimated. While more research is needed before a final conclusion can be reached, circumstantial evidence is strong. The New York Times reported last December that "Methane levels have soared since 2007 for reasons that still aren't fully understood. But fracking natural-gas production, which accelerated just as atmospheric methane levels jumped, is a prime suspect."

Methane is a powerful greenhouse gas, 80 times more potent than carbon dioxide. Although it does break down after about 20 years, this does not help us. Climate research determined that we have only ten years to reduce fossil fuel consumption by half to prevent irreversible climate destruction. Therefore, as Ecology notes, "the Washington Legislature has adopted aggressive limits to reduce our state's emissions in the years ahead."

Permitting the construction of what "would be one of the 10 largest sources of greenhouse gas emissions in the state," would sabotage the emission limits our legislators worked hard to establish. Ecology's Second Supplemental Environmental Impact Statement (SSEIS) shows that "if constructed, the proposed Northwest Innovation Works methanol facility would" be responsible for at least 4.6 million tons of carbon dioxide emissions per year. Nonetheless, the authors of the SSEIS hypothesize in their conclusion that global emissions would be worse without the Kalama plant, based on the assumption that the methanol produced in Kalama would replace methanol produced from coal. That assumption is flimsy, if not misguided. If anything, the current pandemic is teaching us how quickly predictive models can fall apart. Approving the construction of this facility would set us on a dangerous path to irreversible climate breakdown.

Mitigating climate and ecological breakdown requires us to treat the root of the crises. We need to leave carbon in the ground, stop burning fossil fuels, and limit the production of plastics. I am urging Washington's Department of Ecology to step up to the task and stop NW Innovation Works from constructing what would be the world's largest methanol plant in Kalama.

Sources

https://e360.yale.edu/features/the-age-of-megafires-the-world-hits-a-climate-tipping-point
http://www.realclimate.org/index.php/archives/2020/09/new-studies-confirm-weakening-of-the-gulf-stream-circulation-amoc/
(https://www.scientificamerican.com/podcast/episode/greenland-melting-fastest-any-time-in-last-12-000-years/)
https://oceana.org/blog/remote-island-baby-albatrosses-suffer-diet-plastic-trash
https://www.nytimes.com/interactive/2019/12/12/climate/texas-methane-super-emitters.html)
https://www.sightline.org/2020/09/03/new-analysis-proves-kalama-methanol-project-is-a-climate-disaster/
https://www.ipcc.ch/sr15/
https://www.sightline.org/2020/09/23/kalama-methanol-benefits-assume-catastrophic-climate-failure/

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Comment From: Diane Dick

10/08/20 @ 12:50 PM
2020 10 08 Comment #7

Washington State Department of Ecology
Olympia, Washington
Re: Formal Comments on Kalama Manufacturing and Marine Export Facility Draft Second Supplemental Environmental Impact Statement, September 2020

Please deny Kalama Manufact...↓
Greenhouse gas emissions are insufficiently explained in the draft second supplemental environmental impact statement (SSEIS) and the data contains errors and omissions.

The SSEIS asks a basic question. How much CO2e will be produced in refining 3.6 million metric tons of methanol per year?

When science looks at a question and comes up with an answer the usual first response to the answer should be another question. Is the answer reasonable? In the case of NWIW the answer is no.

Looking only at methanol process, from Table 3.5-2 GHG Emissions from On-site Sources, the ULE process and purchased power (the 100 MW demand required for the process) will produce GHG emissions ranging from the low estimate 728,535.7, to mid estimate 915,121, to the high estimate 1,347,803 MT CO2e/year.

The high estimate means 0.374 metric ton of GHG would be emitted for every metric ton of methanol produced. The low estimate yields 0.202 metric ton GHG per ton of methanol.

The methanol industry would likely find these answers ludicrously implausible.

"Ten or more years ago, a typical methanol manufacturing plant would emit about 0.9�1.0 metric tonnes of carbon dioxide for every ton of methanol produced. In addition to the environmental concerns, large CO2 emissions represent operational inefficiencies in a methanol plant, since the carbon emitted as CO2 is not available for making methanol molecules. In fact, excess CO2 from other industrial facilities can also be captured and consumed to increase methanol production. Through the implementation of efficiency improvements and through replacing of older facilities with newer plants that use more efficient technologies, over the last decade methanol plants have been able to significantly reduce CO2 emissions by up to 40%. Some facilities report emissions as low as 0.54 tonnes of CO2 / tonne of methanol produced. This is equivalent to emitting 3.8 lbs of CO2 per gallon of methanol." https://methanolfuels.org/about-methanol/environment/

The ULE process is not new. It is based on a small prototype, the Coogee facility in Australia, operational more than twenty years ago.

Here is what I told Southwest Clean Air Agency about the Coogee ULE process in my comments January 2019 regarding extension of NWIW Kalama's air discharge permit.

"The ULE process is not a conventional methanol process with conventional equipment and has only been used in one small facility that has since been closed, the Coogee Methanol Plant, Laverton North, Victoria, Australia, operated by Coogee Energy Pty Ltd.
https://insider.thewest.com.au/august-2017/power-played/
The best information on the Laverton Coogee methanol process and emissions can be found in Coogee Energy Pty Ltd Methanol Plant Environment Improvement Plan, December 2003. Attached. http://s3.amazonaws.com/zanran_storage/www.coogee.com.au/ContentPages/1245343343.pdf
This was the plant's third improvement plan (EIP). They had problems. They admitted it was an experimental process that needed improvement.
"The Coogee Methanol Plant is Australia's only methanol production facility, and is currently capable of producing between 70,000 to 80,000 tonnes per annum of chemical grade methanol. The plant operates 24 hours a day, 7 days a week, all year round." EIP p. 10 The Coogee methanol plant had capacity to produce in one year what NWIW Kalama plans to produce in 8 days. In other words, the NWIW production capacity is proposed to be about 45 times greater than the prototype on which it is designed.
In 2003 the Coogee plant had been operating almost ten years. Their aim was to produce methanol with greater efficiency and less CO2e emissions. The EIP states in 2002 that 0.781 Tonnes CO2e were produced per tonne of methanol, EIP p. 21. If this emission rate were applied to NWIW Kalama production of 3.6 million tons methanol per year, then NWIW would be emitting 2,811,600 tons of CO2e annually at the refinery site alone, over twice the estimate projected in the ADP."

When scientific inquiry reveals extraordinary results, extraordinary proof is required. The unrealistically low emissions Northwest Innovation Works claims will result from their ULE methanol process demands extraordinary proof. Chemical equations describing a perfect process are not sufficient or realistic.

Demand real world examples the NWIW ULE process will produce the extremely low emissions as claimed on a large industrial scale.

Thank you,

Diane L. Dick
Longview

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Comment From: Teressa Barsotti

10/08/20 @ 12:13 PM
This project is dangerous and potentially disastrous for our region. Keep it in the ground!
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Comment From: Arlene Hobson

10/08/20 @ 11:39 AM
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.

We need to be investing in a livable future that is safe for all to thrive, especially the young people of ...↓

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,
Arlene Hobson
19809 Linden Ave N Shoreline, WA 98133-3514
rleen206@gmail.com
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Comment From: Kathleen Grimbly

10/08/20 @ 11:37 AM
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.

The Kalama is home to Spring Chinook which are crucial food for endangered Southern Resident Killer Whales....↓

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,
Ms. Kathleen Grimbly
4658 Blank Rd Sedro Woolley, WA 98284-8911
bluemoonexplore@gmail.com
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Comment From: Marilyn Cornwell

10/08/20 @ 11:35 AM
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.

The environmental devastation caused by the fracked gas refined into methanol begins right when is fracked ...↓

It is our moral and spiritual obligation to confront the misinformation, speculation, and omissions about the environmental effects of methanol production by NW Innovations Works in the environmental impact statement. The environmental costs to the many far outweigh any profit that will be made by a few.

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,
The Rev. Marilyn Cornwell
9010 SE 47th St Mercer Island, WA 98040-4410
mmcornwell@live.com
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Comment From: Anne Bryant

10/08/20 @ 11:33 AM
I am strongly opposed to the the second Supplemental Environmental Impact Statement (EIS) for the Kalama Manufacturing and Marine Export Facility.

Although I live in Portland, OR and not in the state of WA, the fate of that ancient, venerable river, ...↓

It's enough reason for me to say NO to this project that the Cowlizt Indian Tribe is opposed to this second SEIS. Their assessment is that the project would irrevocably damage their ancestors's cultural resources and already altered natural landscape. It would permanently ruin the lower Columbia and ruin salmon and wildlife habit.

Rather than invest in development of a project that could become a stranded asset in a number of years, why not invest in sustainable jobs for the Kalama area?

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Comment From: Catherine Ruha

10/08/20 @ 11:31 AM
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. We can't...↓

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,
Catherine Ruha
1541 NE 91st St Seattle, WA 98115-3144
ruhac@outlook.com
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Comment From: Hollis Dye

10/08/20 @ 11:30 AM
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. The met...↓

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,
Hollis Dye
PO Box 453 Grapeview, WA 98546-0453
hjdskeezix@gmail.com
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Comment From: Cowlitz County (Ron Melin)

10/08/20 @ 11:26 AM
Please see Cowlitz County's comments attached.
Attachments:

Comment From: Mike Reuter

10/08/20 @ 10:31 AM
I am speaking here as an individual and not as the Mayor of Kalama.

"Natural Gas isn't a Bridge Fuel; it's a Gateway Drug."
John Farrell

According to the Hearing on the Kalama Methanol Refinery in Cowlitz County on page 9/30, it states:

The project would...↓

How will we ever lower our dependence on natural gas if one company's demand is equal to 1/3 of the entire State of Washington? Is this refineries expected 30- 40-year lock on natural gas really a way to move us away from fossil fuels?

I know that the people who work at The Department of Ecology say that we can just let this one go through. This seems like the best of the worst. This is the wrong kind of thinking; this one approval means multiple massive fossil fuel projects will make your jobs even more distressing. This will open the floodgates of new endeavors of fossil fuel projects; the thin green line would be broken. The word would get out; they have found the key to open the gates.

Policy decisions need to be made on the most effective hierarchical order of gas allocation between domestic and foreign sectors to facilitate economic development and prosperity for all SW Washington.

The Climate Crisis Requires That We Move Away from Gas
June 26, 2019, Sheryl Carter Bobby McEnaney
These are long-term, expensive investments that have a good chance of becoming uncompetitive, or economically "stranded," since there is much cleaner, cost-competitive (or soon to be) alternatives to reach our climate goals. That means we will still be paying for these investments long after they are no longer economically or environmentally viable, resulting in higher energy bills, lost jobs, and financially unstable utilities.

I will never understand why we spend millions of dollars in energy-efficient appliances in homes, use low flow toilets and washers, and insulating our homes and businesses to save on gas heating only to have one company come in and take all of the savings. This company should reimburse the citizens and businesses the millions of dollars that have already been invested trying to reduce our carbon footprint.

Having one company take 100MW of power, 320 million therms of natural gas, and 4 million gallons per day is an astronomical amount of our NW resources. I think that's why there has never been another ULE methanol refinery built since the prototype 30 years ago; no country can give up that much of its limited resources. How many companies will not be able to use these essential non-renewable resources when they are desperately needed years down the road?

This project's shortfall would be a great documentary film that will probably be seen on Netflix. It has all the makings of extreme short-sightedness of elected officials and agencies not unheeding the warnings that were supposed to protect the people of Washington for centuries, and not just for decades. People have already started thinking of which actor or actress that will be playing their part.

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Comment From: Don Steinke

10/08/20 @ 10:17 AM
Although you seem to be limited to GHGs, you cannot ignore the seismic risks of this project.
When EFSEC and Gov Inslee rejected the Tesoro Savage oil terminal proposed in Vancouver, they didn't base their rejection on climate, they based it on seismi...↓
We heard from a geology professor that the seismic risks in Kalama were identical to Vancouver.
He said that although the boundary of the subduction zone is off shore, the actual place where the plates would get stuck could be right under Kalama.
That risk cannot be mitigated.
Furthermore, when we have a major seismic event, (we're overdue) and the pipeline ruptures and the refinery, what number would you assign to the emissions.
It is not if but when. It is likely to be larger than any seismic event in California.

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Comment From: Don Steinke

10/08/20 @ 9:34 AM
You cannot allow the DSSEIS to stand as is without knowing who monitors the pipeline for leaks and how soon they repair Class 3 leaks.
In this story, from Franklinville NY, we learn that there were three classifications of leaks. And we learn that a ...↓
https://www.niagara-gazette.com/news/local_news/southern-tier-pipeline-leak-response-stirs-local-concern/article_f4824e45-2ce7-5e1f-9487-b84f4f66d210.html

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Comment From: Pillip Norman

10/08/20 @ 9:22 AM
This is not an energy project in service to any local users deserving of state respect. The project imagined is purely is purely a forbidden export scam. Public commons are exploited and ruined forever, so that greedy investors in charge of a theft, ...↓
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Comment From: Cowlitz Indian Tribe (Phillip Harju)

10/08/20 @ 7:35 AM
The Cowlitz Indian Tribe has reviewed the revised Port of Kalama Draft Second Supplemental Environmental Impact Statement. Attached are our comments.
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Comment From: Cynthia Svensson

10/08/20 @ 6:26 AM
Dear Mr. Rich Doenges,

Here are my comments about the DSSEIS:

1. As a resident of Kalama, the State of Washington, and the Pacific Northwest I do not find any reassurance in the meager mention of mitigation plans in the DSSEIS. The plans need to be s...↓

2. I know that this plant would be in Washington and that you work for the State of Washington. Still, there are people in Oregon living closer to the proposed plant than most citizens of Kalama. They need protection and they have not even been mentioned let alone considered in mitigation or safety plans. Do we need to drag the State of Oregon into the discussion? Let's just be good neighbors and insist that NWIW do the right thing by mitigating GHGs in Oregon, as well, and include that in the mitigation plan.

3. I don't believe I saw water mentioned as a GHG in the DSSEIS and yet it is a big player when localized in a giant plume over a relatively small area. Recent wildfires really brought air quality issues to the forefront with unhealthy to hazardous conditions in the area. Now imagine a plume helping to seal that in. Sadly, if our experience with the Tillamook Burn is any indicator, we can expect more wildfires in the next several years just because of fire-dried forests. Please, give some consideration to water as the GHG that it is.

4. Please recheck the mileage used for the pipeline distance from the fracking fields to Kalama. I don't believe it will be possible to put in pipe "as the crow flies." The actual distance may raise figures by 50%.

5. How many GHGs are released in the average pipeline explosion? How often do the explosions happen? How is that correlated to the age of the pipeline? We have had an explosion very near Kalama. There was a bad one in Bellingham not too long ago. How many GHGs were released? This estimate needs to be added in to the GHG volume, if it has not already been done.

6. The DSSEIS has spent a lot of time on market analysis and comparing different processes. Unfortunately, there is one key process for which we have no data. The ULE has been tried in a pilot plant but never on a large scale, and certainly not on a World Class scale. There is a reason that the Methanol Industry has not taken up the ULE process and I don't believe it is just about profit. It is simply too big a risk for too little gain. It may not be any cleaner at all if the electricity needed to run the process is from fossil fuel rather than hydro and if the use of hydro causes some other user to have to turn to fossil then there may be no savings at all.

7. The DSSEIS proves that there will be huge amounts of GHGs produced in the State of Washington. No one can prove that producing those GHGs will result in the failure to produce an equal amount of GHGs elsewhere. In an expanding market, which the DSSEIS fully stands by, the Kalama GHGs will be added to the ever growing amount of GHGs on the planet. Someone who is making good money doing something is not going to stop that venture just because someone else starts to make the same product. As long as there is money to be made, the first guy will keep going. There is money to be made by using cheap coal as feed stock or fuel in China and that will continue no matter what we do here in the State of Washington.

8. The DSSEIS reports that at least some of the methanol will possibly be burned as fuel. Thank you for considering that. Of, course, all of it can be burned as fuel. Please use figures reflecting all of it as fuel because even if it goes for olefins, it will free up other methanol to be used as fuel.

9. I know the DSSEIS is about GHGs and I have focused on that, but please, don't forget the many other problems that this proposed methanol plant would create such as 7 times the ASIL for DPM generated by the tugs needed to control the Panamax tankers. We already have so much DPM in our air from !-5, the railroads, and ship traffic. Please, don't let anyone add to that and then seal the whole mess in under a vapor plume.

Thank you,

Cynthia Svensson
MS Chemical Oceanography, U. of W.
Kalama resident

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Comment From: Diane Dick

10/08/20 @ 6:26 AM
2020 10 08 Comment #6

Washington State Department of Ecology
Olympia, Washington
Re: Formal Comments on Kalama Manufacturing and Marine Export Facility Draft Second Supplemental Environmental Impact Statement, September 2020

Please deny Kalama Manufact...↓
Greenhouse gas emissions are insufficiently explained in the draft second supplemental environmental impact statement (SSEIS) and the data contains errors and omissions.

The data on purchased power is incorrect and based on speculative assumptions.

Purchased power is detailed in Appendix C of the SSEIS and includes the following:

"Purchased power
The proposed project will import 100 MW (864,000 MWh) of electric power from the regional power market through the Cowlitz PUD transmission system during continuous operation. Power demand is reflected in Megawatt Hours (MWh). Total power demand is shown in Table C-17 for the ULE Alternative. Power demand over the 100 MW provided by purchased power is provided for by the on-site natural gas combustion turbines (emissions from the on-site power generation are captured in the ULE Production Scenarios)." P. C-20

"Electrical power demand
Electrical power will be required for KMMEF operations. A portion of the power required will be generated from onsite combustion turbines, and the rest, estimated to be 100 MW by NWIW, will be purchased from the power market. Emissions from electrical generation by the onsite combustion turbines are included in the emission calculations for methanol production for the ULE alternative. Emissions for the 100 MW of purchased power are based on three generation scenarios:
• Low Scenario. All purchased power is generated from renewable sources. The current renewable mix from Cowlitz PUD is 86% hydroelectric, 8% nuclear, and 6% wind.
• Mid Scenario. Purchased power is from a mix of generation sources, which changes over time in line with the expected, future energy mix in accordance with the Washington State Clean Energy Transformation Act (CETA) signed into law on May 7, 2019. In the mid scenario, generation from 2020 to 2030 is from the current marginal power source (defined as the source of electricity that is first or cheapest available to meet an increased power demand), generation from 2030 to 2045 is from a mix of 20% marginal power and 80% renewable power, and generation from 2045 and beyond is all from renewable sources.
• High Scenario. Purchased power is all from the current marginal power source.

A NW Power and Conservation Council study of CO2 emissions in the NW power system published in 2018 concluded that the expected emissions over the time frame of the project from marginal power sources were in a range that correlates well with the emissions from a combined cycle natural gas-fired powerplant. Therefore, for the purposes of this study, a combined cycle natural gas-fired powerplant was assumed as the current marginal power source.
Emission factors for combined cycle natural gas-fired powerplants, hydroelectric generation stations, nuclear powerplants, and wind turbines were derived from GREET and are shown below in Table C-1." SSEIS p. C-3

Table C-1 shows range of emissions from power purchases from low to high scenarios. [extracted data]
Purchased Power GHG Emission Factors (g/kwh)
CO2e 0.61 216.57 431.43

The 864,000 MWh from 100 MW demand for continuous operation is incorrect. Multiplying 24 hours of 100 MW demand for 365 days yields 876,000 MWh.

As noted in a previous comment, nowhere in the SSEIS are the electrical power requirements and sources for operating the KMMEF marine dock, including shore power provided to over 80 vessels at berth annually, evaluated. The GHGs generated from this power and marine dock vessel operation are not evaluated.

Based on scenario descriptions above, GHG emissions from on-site purchased power range from 526.7 for low estimate, 187,112 mid estimate, to 372,752 MT CO2e/year for high estimate per Table 3.5-2.

So which of the electrical power resource scenarios and resulting GHG emissions are most likely and reasonable?

All the estimates are low given the absence of including KMMEF dock operations and error in calculating the hours of operation in a year.

The low estimate is unlikely given a large new industrial load will not be allowed as a priority customer for Cowlitz PUD's hydropower resources. NWIW will be required to purchase power from the open market.

The mid estimate is speculative based on the ability of current electrical power resources to move towards clean and renewable resources. [It is also speculative dirtier generation from coal will be replaced by arguably cleaner gas generated electricity given the huge amount of gas NWIW will be sucking out of the limited PNW gas infrastructure.] It is speculative and dubious NWIW will even be operating at the farthest time frame that includes the cleanest power.

The high scenario, with estimate of 372,752 MT CO2e/year by using current marginal resources, is the most likely and reasonable number to work with.

To put the high scenario GHG emission number in larger context, the EPA GHG calculator states 876,000,000 kWh of electricity produces 619,367 metric tons of CO2e.

Refining the power resource further, the following is the result from 2018 eGRID data for the same amount of electricity:

"Using the eGRID subregion NWPP (WECC Northwest) emission rates and 4.80% percent line loss, your estimated annual use of 876,000,000 kWh of electricity results in 586,632,672 pounds CO2, 367,219 pounds SO2, and 550,829 pounds NOX emitted in one year from the power plants in your area.
It would take 6,896,152 seedlings grown for 10 years or 313,053 acres of forests in one year to offset those CO2 emissions."
https://www.epa.gov/egrid/power-profiler#/NWPP

Converting the above to metric tons, the CO2 alone represents about 262,000 metric tons of GHG. Nitrous oxide has 298 time the global warming potential of CO2. https://climatechangeconnection.org/emissions/co2-equivalents/

Even the estimate of GHGs from purchased electrical power for on-site consumption in the high scenario is lowballed. Please redo the purchased power calculations and emissions to reflect reality.

Thank you,

Diane L. Dick
Longview

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Comment From: Mark Uhart

10/08/20 @ 6:14 AM
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Comment From: Sally Keely

10/08/20 @ 5:17 AM
DSSEIS Table 3.5-11 states KMMEF will emit approximately 4.6 million metric tons of CO2e per year, every year, for the 40 year planned lifetime of the Kalama Methanol Refinery. There is simply no way to mitigate this level of climate pollution. Per t...↓
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Comment From: Robert Wagner

10/08/20 @ 4:49 AM
Hello, I am glad The Department of Ecology extended the comment period giving me the opportunity to voice my opinion on this critical SSEIS. This is critical to me because I am concerned about the negative impacts of the NWIW methanol project on my ...↓

I am not a scientist but I have reviewed the SSEIS as best I could and done some homework on some of it's conclusions. While there are many questions that the study answers and raises, I came away with two major concerns/questions.

First of all the study notes that the plant would produce 4.6 million tons of carbon emissions per year for potentially 40 years. It is my understanding that this would put it in the top ten of Washington industries that emit green house gases. To me this is totally inconsistent with our States goals of reducing green gases and the rate of global warming. Our State has pledged to work towards these goals but allowing this type of project makes the pledge hollow. Are we serious about our goals?

My second major concern is the lack of commitment and/or a plan that NWIW has for mitigating the impacts of it's plant. To me this would be a critical element of the SSEIS and leaving it vague and voluntary is a recipe for disaster. Apparently NWIW has already been less than honest about it's intent for the uses of the methanol, plastics or fuel, and so nothing should be left to chance.

In closing I believe it is in the best interest of my community and my State that your department deny the shoreline permit for the NWIW project. This project needs to be rejected if we truly want to protect our local and global communities.

Sincerely, Bob Wagner, Longview Washington

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Comment From: Bob Carroll

10/08/20 @ 4:05 AM
I am in favor of the NWIW Kalama Methanol project. the science shows that methanol (which we have need of) will be produced with no liquid discharge and severely reduced emissions. it is better to produce it here in this way instead of it being produ...↓
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Comment From: Joana KIRCHHOFF

10/08/20 @ 3:20 AM
Stop Kalama and stop environmental degradation!!!!
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Comment From: Kathy Boylan

10/08/20 @ 3:17 AM
My sister and I are sending you a strong message about Kalama. Stop the project, save the salmon, save the environment!
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Comment From: M Judith Ferguson

10/08/20 @ 2:57 AM
Director Watson, Regional Director Doenges and Department of Ecology staff –

Thank you for your issuance of a 2nd SEIS on the Northwest Innovation Works (NWIW) Methanol refinery in Kalama after finding the project's initial submissions inadequat...↓

My fervent hope is that your Department will reject the project and deny Shoreline permits based on your new analysis, as well as the 'climate change' summer we have experienced this year - from the wildfire devastation on the west coast to the hurricane and derecho destruction in the Gulf and Midwest. It is an unfortunate truth that NWIC is a Chinese owned company that lies to regulators and the public. They enticed the Port of Kalama and Cowlitz County to sacrifice the health, safety and long term viability of the Columbia River ecosytem for profits and promises that may never be realized. NWIW cannot be trusted to mitigate negative impacts of this fracked gas refinery. The fact that this project had to abandon its initial Tacoma siting due to outspoken community opposition and is facing equal opposition and additional reviews in Kalama is a 'red flag' indicator that there is something wrong with it at its core. I appreciate that you addressed the likelihood that methanol produced in Kalama will be used as transportation fuel, despite deliberate efforts by NWIW to mislead your agency and the public that it would be used solely for plastics manufacturing.

Your new SEIS analysis reveals what the NWIW backers have long denied - that the refinery would cause more methanol to be burned as fuel in China and result in significant methane pollution from fracking. The methanol refinery would quickly become one of Washington's most significant sources of climate-changing pollution and use more fracked gas than all of Washington's gas-fired power plants combined. If built, our state will be locked into decades of additional climate pollution, even though we know it's 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. As Governor Inslee stated, we cannot support such fracked gas projects in good conscience.

When I read the Public comments of so many others who are equally concerned, I feel hopeful. The pandemic has impacted systems and business practices across the board, as well as altered assumptions at many levels. Uncertainty and volatility abound in energy market dynamics, and the predictability of global fuel markets, technology development, consumer behaviors or regulations of any kind are equally uncertain. For those same reasons, one must not expect that what NWIW states they will or won't do will actually come to fruition. Talk is cheap and actions speak loader than words.

I am concerned that your SEIS provides too little detail on the actual mitigation that would be accomplished within the VMPF framework – and concerned that NWIW is the 'architect of the voluntary program.' Does this mitigation address the full impacts of NWIW's overseas emissions?. Without defined benchmarks to achieve, it can't be expected that NWIW will address issues in a forthcoming, transparent manner. Once in operation, the NWIW's working relationship with the State of Washington could abruptly change, as could the plant's operational plan. Promises to the community and State regarding mitigation, etc. could easily be dismissed and abandoned.

I do have four questions/concerns that I would like you to consider:
#1 - Have emissions from activities at the adjacent dock and wharf site been included in your analysis?
#2 - In regard to SW Washington Clean Air Agency, will they be monitoring the cumulative emissions of the methanol refinery in conjunction with the emissions of the other commercial industries in the area? It is my understanding that Puget Sound Clean Air Agency in my Port of Tacoma area monitors only individual emissions of each facility and does no monitoring of the cumulative emissions in the air. In addition, the Agency only monitors certain emissions and not all emissions. It may be that the list of monitored emissions needs to also be updated as the current list may not be capturing newer pollutants. I assume that such an update would need to be instigated by the State of Washington.
#3 - Wilma Subra spoke in Tacoma in 2016 regarding the initial proposed plant and expressed concern regarding the measuring of emissions during startups, shutdowns, testings and flarings. Will all emissions during these procedures be monitored or will some be 'self reported' or not reported at all? It's my understanding that these types of emissions do happen on a frequent basis and are most likely not reported. I would hope that their reporting would be mandated. NWIW's 10/30/2019 letter to Dr. Placido is vague to me in its 'mitigation list of emissions' on page 2.
#4 – September 2020's week of hazardous air quality throughout the region due to smoke and an inversion layer may be a precursor of events to come. What regulations will be put into place to ensure that the Methanol facility does not contribute to increased human health risks in similar situations? Will a facility shutdown be mandated in such cirucumstances?

Should this Refinery be completed, a local ecosystem will be forever altered - - this time by a Refinery that will be the largest in the world and whose operation will contribute millions of tons of greenhouse gas pollutants yearly for 40 years. It is profoundly inconsistent with achieving Washington's climate goals.

Thank you again for initiating a 2nd SEIS on the Methanol facility. I appreciate the opportunity to share my concerns about this Refinery yet again. I do hope that you will deny the Shoreline permit. The Methanol refinery is a project that was/is a bad fit for both the Port of Tacoma and the Port of Kalama.

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Comment From: David Hupp

10/08/20 @ 1:42 AM

Washington State Department of Ecology:

I testify again in opposition to the proposed Northwest Innovation Works (NWIW) Kalama Manufacturing and Marine Export Facility in any form. NWIW proposes a similar facility in Oregon and I oppose that as well. ...↓

The entire document, but particularly the sections dealing with economics (the profession in which I was trained) is written with slick, but dehumanizing language that reminds me of a quote I encountered a couple of years ago:
""Spills can have both positive and negative effects on local and regional economies over the short- and long-term ... spill response and clean-up creates business and employment opportunities for affected communities ... . The net overall effect depends on the size and extent of a spill, the associated demand for clean-up services and personnel, the capacity of local and regional businesses to meet this demand, the willingness of local businesses and residents to pursue response opportunities."
Source: "Trans Mountain [oil pipeline] Expansion Project, Risk Assessment and Management of Pipeline and Facility Spills", volume 7 of Kinder Morgan's Application Pursuant to Section 52 of The National [Canada] Energy Board Act proposing to triple pipeline capacity.

This absurd statement is manufactured by people who have lost their humanity. The sort of "economics" perpetrated in the second draft SSEIS connects to another absurdity inherent in this market-fundamentalist economic philosophy: the national accounts (e.g. Gross Domestic Product) reckon a polluting manufacturing process productive, with no subtraction for the human and community harm caused by the pollution. If the pollution is cleaned up, that also is considered productive. Thus both the process producing the pollution and the process for cleaning it up are "income".

The economics philosophy behind the SSEIS is rancid and inhuman and leads to great harm. The NWIW promises of "jobs" and "mitigation" should be seen in this light.

David Hupp
Hood River OR
October 7, 2020

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Comment From: Christopher Lish

10/08/20 @ 12:02 AM
Thursday, October 8, 2020

Attn: Rich Doenges
NWIW SSEIS
Washington Department of Ecology
PO Box 47775, Olympia, WA 98504-7775

Subject: Don't allow the world's largest fracked gas-to-methanol refinery to harm our climate and Kalama -- Kalama Manufacturing ...↓

To Washington State Department of Ecology:

I strongly urge Washington State to reject Northwest Innovation Works' (NWIW) proposal to build and operate the world's largest fracked gas-to-methanol refinery in Kalama, Washington.

"Our duty to the whole, including to the unborn generations, bids us to restrain an unprincipled present-day minority from wasting the heritage of these unborn generations. The movement for the conservation of wildlife and the larger movement for the conservation of all our natural resources are essentially democratic in spirit, purpose and method."
-- Theodore Roosevelt

The project would use more fracked gas than all of Washington's power plants, combined. The company has sought to mislead regulators and the public about the purpose and impact of the refinery, falsely claiming that the project will displace "dirtier" forms of fossil fuels. We know that fracked gas is a potent greenhouse gas pollutant, and we are counting on Ecology to accurately account for the project's upstream emissions as well as the downstream pollution from the likely combustion of NWIW's methanol for fuel.

"As we peer into society's future, we--you and I, and our government--must avoid the impulse to live only for today, plundering for our own ease and convenience the precious resources of tomorrow. We cannot mortgage the material assets of our grandchildren without risking the loss also of their political and spiritual heritage. We want democracy to survive for all generations to come, not to become the insolvent phantom of tomorrow."
-- Dwight D. Eisenhower

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. We are counting on you to stop this dirty and dangerous project.

"A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise."
-- Aldo Leopold

Thank you for your consideration of my comments. Please do NOT add my name to your mailing list. I will learn about future developments on this issue from other sources.

Sincerely,
Christopher Lish
San Rafael, CA
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Comment From: William Forbes

10/07/20 @ 8:23 PM
There is no excuse for building more plastics manufacturing infrastructure when there is no longer any way to recycle plastics! This is clearly unsustainable and Washington deserves better. It's as simple as that. Just look at your own weekly trash a...↓
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Comment From: Columbia Riverkeeper (Miles Johnson)

10/07/20 @ 5:00 PM
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Comment From: Margaret Cemulini

10/07/20 @ 5:00 PM
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Comment From: John Flynn

10/07/20 @ 5:00 PM
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Comment From: James DeCorsey

10/07/20 @ 5:00 PM
Don?t allow the world?s largest fracked gas-to-methanol refinery to harm our climate and Kalama!
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Comment From: Greg Thiessen

10/07/20 @ 5:00 PM
Don?t allow the world?s largest fracked gas-to-methanol refinery to harm our climate and Kalama!
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Comment From: R. David Goldberg

10/07/20 @ 4:56 PM
"The accelerating threat of climate change and the emerging science on the damaging impacts of natural gas production and distribution mean we must our full efforts on developing clean renewable, and fossil-fuel free energy sources."

-Gov. Jay Inslee
M...↓
Coming out against
the Kalama methanol
project.

Washington state has plans to reduce GHG emissions 45% below 1990 levels by 2030 and 95% below 1990 levels by 2050. To have a chance of hitting these goals it is necessary to find cleaner, renewable alternatives to fossil-fuels. This kind of thinking is necessary for solving the climate crisis. But it is the kind of thinking absent from the Kalama SSEIS when it states it is "not possible" to consider possible alternatives to the use of methanol. The SSEIS feels confident in predicting market trends 40 years out but is blind to Chinese policy makers setting different goals in the near future. Case in point: the Chinese government recently announced the goal of becoming carbon neutral by 2060. The market displacement theory put forward by the SSEIS is the current status-quo. But we need bold visionary thinking to solve the climate crisis. Too bad that thinking isn't coming from the Washington Department of Ecology.
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Comment From: Linda Horst

10/07/20 @ 4:41 PM
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...↓

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 all most 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.
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Comment From: Don Steinke

10/07/20 @ 3:08 PM
To recap:
The DSSEIS for Kalama methanol:
Relies on a trust that other countries will not establish policies that alter the market for energy and plastic.
Fails to recognize that countries around the world are banning various types of plastic.
https://ww...↓
Fails to recognize that California now requires 50% recycled content in soda bottles.
Does not verify assumptions of methane leaks from pipelines
Does not account for abandoned wells that will leak methane forever.
Does not acknowledge that pipeline companies don't bother to repair pipeline leaks promptly unless there is a threat to public safety.
Does not acknowledge that China is committed to begin reducing emissions in 2030, and be carbon neutral by 2060.
Does not consider Inslee's Clean Air Rule
Does not consider HB2311, which establishes a state goal of 45% below 1990 levels by 2030.
Does not account for the emissions associated with ships while docked.

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Comment From: Columbia Riverkeeper (MILES JOHNSON)

10/07/20 @ 2:26 PM
Attached please find 5 exhibits to the comments of Columbia Riverkeeper et al.
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Comment From: Catherine Bax

10/07/20 @ 2:26 PM
Thank you for the opportunity to comment on this very disturbing project that is being pursued by Northwest Innovation Works (NWIW) in Kalama. My name is Catherine Bax. I am a retired medical professional and a resident of Oregon.
I do not want to se...↓
The only path forward for our long-term survival on this planet is a low carbon future. The vast majority of scientists who study climate change and our experience as people in the 21st Century tell us this. Washington state has set some thoughtful clean energy and climate goals. This project is not consistent with those goals. NWIW's refinery would produce 4.6 million tons of greenhouse gas pollution each year, for 40 years, a staggering quantity of pollution that will undermine Washington's greenhouse gas reduction goals.
The idea that a NWIW methanol refinery in Kalama, Washington could produce less pollution and GHG's than another high carbon factory somewhere else (in China?) is speculative, tenuous and ridiculous. A project (Kalama Methanol Refinery) that will produce tons of pollution, but less than an existing project that is producing more pollution is not a good reason to go forward with the project (Kalama Methanol Refinery) that produces tons of pollution. You can always find something that is worse than the terrible thing you want to do. Neither project is acceptable. Future energy needs do not need to be met by fossil fuels. There are alternatives if you and I demand them.
Kalama needs economic stimulus and good jobs for the people who live there. But projects that profoundly contribute to global warming, ocean warming and rising shorelines are not the answer for Kalama, for Washington State, for the Pacific Northwest or for the planet. There are alternatives if we demand and support them.
I implore you, The Washington State Department of Ecology, to reject NWIW's methanol refinery project and to deny the Shoreline permits for the project.
Catherine Bax

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Comment From: Columbia Riverkeeper (Miles Johnson)

10/07/20 @ 2:19 PM
Please see attached comment letter from Columbia Riverkeeper and 31 other regional and national environmental, climate, and faith organizations. Word version attached for ease of use and because the links are live in that format. Exhibits to follow.
Attachments:
Download
Download

Comment From: DeeAnna Holland

10/07/20 @ 12:17 PM
I actually live just a few minutes away from the proposed location which means I will have to experience whatever pollution and damage this facility will create. It was bad enough growing up across the river from an active nuclear power plant and the...↓
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Comment From: Julie Martin

10/07/20 @ 11:24 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.
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Comment From: Akaya Kreger

10/07/20 @ 8:31 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.
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Comment From: Greg Martin

10/07/20 @ 8:06 AM
The proposed project runs counter to climate-related statutes and aspirations in our region and poses a serious environmental danger. First, the SSEIS clearly shows that the project in itself would substantially increase greenhouse gas emissions. Fur...↓
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Comment From: James Bruckner

10/07/20 @ 8:01 AM
Dear Decision-Makers at the Washington State Department of Ecology and other responsible Decision-Makers;
Regarding the proposed permitting of the methanol plant in Kalama, WA:

Your commission is to protect the air quality in Washington State. Will per...↓

Your charter is to protect the air quality in Washington State. If "the Kalama facility would be one of the 10 largest sources of greenhouse gas emissions in the state", will you fulfill your charter?

Your ethical responsibility is to preserve the good air that we have in Washington State so that it does not become more like the air in China (where my son lived for three years and still suffers lung distress). Will trading carbon emission chips with China fulfill your responsibility to the citizens of Washington State?

Do you trust China to reduce their methanol production emissions in exchange for our increase in CO2 in a world that demands more methanol? Is this a good bet for reducing world carbon numbers, or is it a deal with the devil? Isn't it your job to protect our air, in Washington and world-wide? Where is your political logic?

Do you trust the onsite Chinese managers and chemical engineers to have Washington State air quality in mind, when compared to their own, it will still seem pristine to them after the "almost 1,000,000 metric tons" per year (= 2,204,640,000 pounds) have been added to our air. Chinese companies are ultimately managed by the Chinese government and its billionaires. Do your job please. Stop this backward thinking.

Has Homeland Security weighed in on this proposed methanol site? Will it be a good policy to allow a Chinese managed plant to sit on the only narrow piece of land where the three corridors of commerce come very close together? Interstate 5, the Columbia River, and all the North-South rail-lines converge exactly on this site. Will you let the Chinese build this bomb on this regional corridor? Have you heard of Beirut in the news lately?

This failure in leadership and foresight does not need to be your legacy. The banal corruption of leadership for profit is a never-ending story. Your job is to protect the clean air of Washington State, not to add 2 trillion pounds of CO2 per year to it. Please fulfill your charter, commission, and ethical responsibility.

Sincerely,

James K. Bruckner, Ph.D.
149 Date Street
Kalama, WA 98625

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Comment From: Bea Ogden

10/07/20 @ 6:56 AM
I do not support fracking, the export of natural gas, nor the building of natural gas pipelines. These are all incredibly dangerous and destructive to the environment.
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Comment From: Mike Reuter

10/07/20 @ 5:48 AM
I am speaking here as an individual and not as the Mayor of Kalama.

I am having concerns about how many verbal promises the Kalama methanol officials making to the local elected leaders like this one stated at the Cowlitz County Commissioner Debate be...↓

What can you do to open public lands in Cowlitz County if elected?

Commissioner Weber replied at 22:53 of the video, "The third area is one that is intriguing and it involves the methanol plant. As you remember, the Kalama methanol plant carries within it a promise and expectation from the company that they will mitigate 100% of the cost of the fossil fuel that they used in the production processes to the tune of about $8 million dollars a year.

They have at least verbally that they would like a lot of that, if not all, of it, spent here in Cowlitz County to help build appropriate quality of place activities. So, you get that by supporting that application and getting that mill built.

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Comment From: Sara Drescher

10/07/20 @ 5:37 AM
The proposed Kalama methanol plant would have severe negative health impacts for Washingtonians. As we grapple with the impacts of climate change, with the entire state under hazardous amounts of smog for much of September, it is reckless to consider...↓

This project will harm human health. As a physician, I cannot condone to building of this plant in our state.

Sara Drescher, MD
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Comment From: William Falk

10/07/20 @ 5:25 AM
This project would easily be one of the worst polluters in our state. The Kalama Methanol project is an environmental disaster in the making. This project will rely on an enormous amount of fracking to provide gas to make ethanol. This would be a cat...↓

This project makes no sense financially or environmentally. I strongly object to this project and urge our NW policymakers to oppose it.
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Comment From: Robert Brown

10/07/20 @ 4:53 AM
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. Climate...↓

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,
Mr. Robert Brown
1443 Edwards Ave Fircrest, WA 98466-6640
larkbrown@comcast.net
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Comment From: Bonnie McKinlay

10/07/20 @ 4:18 AM
In the words of Washington State Governor Jay Inslee, "Climate change is a matter of great peril but also one of great promise. We can pioneer the industries of the future, create millions of good-paying jobs, and build the clean energy economy of th...↓
Listen to your governor, do not accept the Kalama Manufacturing & Marine Export Facility.

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Comment From: Bonnie McKinlay

10/07/20 @ 4:08 AM
Thank you for accepting public comments on this crucial issue.
It boggles my brain to think that there is a possibility that Washington state which has benefited economically from science, can consider approving the Kalama Manufacturing & Marine Expor...↓
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Comment From: Shelley Hickman

10/07/20 @ 4:07 AM
The methanol plant proposed/rammed down throat here in Kalama is astoundingly stupid. This project was planned and marketed before any input from local citizens. This plant will be below my house and that means that whatever is being discharged from ...↓
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Comment From: Evergreen Carbon (Wolf Lichtenstein)

10/07/20 @ 4:02 AM
Comments attached.
Attachments:

Comment From: Shary B

10/07/20 @ 3:09 AM
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,
Ms. Shary B
1950 Alaskan Way Seattle, WA 98101-1075
shary50@yahoo.com
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Comment From: Marian Karpoff

10/07/20 @ 3:07 AM
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. We must ...↓

Sincerely,

Marian Karpoff

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,
Marian Karpoff
11 W Aloha St Apt 702 Seattle, WA 98119-4743
fdmkarpoff@gmail.com
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Comment From: Alison Vrbas

10/07/20 @ 3:06 AM
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. It is ti...↓

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,
Alison Vrbas
4513 49th Ave SW Seattle, WA 98116-4041
AliMVrbas@hotmail.com
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Comment From: Carolyn Urban

10/07/20 @ 3:04 AM
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.

I want a ...↓

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,
Carolyn Urban
11 W Aloha St Apt 501 Seattle, WA 98119-4741
curbanjgow@gmail.com
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Comment From: Julie Henling

10/07/20 @ 3:03 AM
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,
Julie Henling
4816 NE 47th St Seattle, WA 98105-3819
jhenling17@gmail.com
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Comment From: Dimitri Stephanopoulos

10/07/20 @ 2:42 AM
I light of the recent IPCC report on the impending climate chaos and doom it would be completely foolhardy to go forward with this project. Please consider what this would mean for a warming planet. Nothing is more important now then reducing greenho...↓
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Comment From: Alexandra Richardson

10/07/20 @ 2:40 AM
This refinery would cause measurable and severe respiratory health problems due to air pollution to thousands of Washintonians and Oregonians, would harm iconic NW salmon and orca populations,and will fast-track our corner of the world to the climate...↓
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Comment From: Woodland Chamber of Commerce (Janice Graham)

10/06/20 @ 5:00 PM
Attachments:

Comment From: Devon Kellogg

10/06/20 @ 4:56 PM
Department of Ecology:

As a parent, teacher, and longtime WA resident, I am deeply concerned about the effects of adding more greenhouse gasses to our atmosphere, increasing global temperatures and denying the children I raise and serve a stable clima...↓

Already we are experiencing the severe and costly effects of our warming world. We know from IPCC SR1.5 that we have just 10 years to reduce the offending emissions by 50% or more for our best chance at avoiding the worst effects. We cannot afford to add any more warming gasses to the mix!

For this proposed facility, fracking the gas, leaking it for transport, then producing methanol which is then shipped overseas to be used to make plastic is dirty, unhealthy and harmful at every step of the process. Permits for this project must be denied.

Thank you for your attention to this critical and urgent matter,
Devon Kellogg
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Comment From: JJ L

10/06/20 @ 4:16 PM
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.
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Comment From: Mike Reuter

10/06/20 @ 4:08 PM
I am speaking here as an individual and not as the Mayor of Kalama.

This methanol refinery is a way for Canada to be able to export natural gas to world markets and will cause catastrophic higher energy costs to the NW consumers and businesses by poss...↓

This article below shows Northwest Innovation Works is using this methanol for fuel and how this project is just a way to monetize and release large amounts of stranded Canadian natural gas. I have also enclosed a document showing that exporting natural gas benefits only a small and narrow portion of the U.S. economy, and not in the interest of the public (consumers and economy at large).

Liquid-rich gas production: An imperative opportunity for Canada
13 Feb 2018 Mary Hemmingsen, EVP and CFO, Northwest Innovation Works

When it comes to gas monetisation, Canada is looking for new approaches to remain competitive against the mature exporting markets. NorthWest Innovation Works is a multi-national partnership, committed to meeting the global need of a cleaner source for methanol production. This new technology will not only reduce the global carbon footprint but also introduce new gas monetisation techniques to Canada.

Ahead of the Canada Gas and LNG Conference and Exhibition, 14-16 May, Gastech Insights spoke with Executive Advisory Board Member and Executive Vice President & CFO at NorthWest Innovation Works, Mary Hemmingsen, to discover more about the organisation and what these new opportunities mean for Canada's gas industry.

Gastech Insights: NW Innovation Works is committed to meeting a global need for clean-burning liquid fuels and clean feedstock for petrochemical industry. Can you tell us more about methanol as a clean and versatile energy carrier?
Mary Hemmingsen: Methanol's versatility leads to many important applications as a clean and multipurpose fuel and feedstock: in marine and ground transport, power, heat and petrochemical applications. Adding to this versatility, methanol exists as a clear liquid form in ambient conditions, that is water soluble and biodegradable, ensuring easier and safer shipping and distribution.

Methanol demand is expected to increase steadily through 2035, in part, driven by increasing MTO demand with low-cost gas-based manufactured methanol that is more competitive to coal-based methanol. This rapid rise in MTO is led by China, driven by opportunities in the value chain and for improved environmental performance. Among the fuel applications being expanded is the:

• Marine Sector: Currently consumes 370 million metric tonnes of bunker fuel per annum. IMO standards on SOX & NOX emissions are required to be met by 2020 with methanol poised to capture at least 20% of this market based on methanol's attributes of cost-effective lower emission output.

• Ground Transportation Fuel: China, with others following, is leading the growing utilization of methanol as a clean fuel for transportation. Methanol standards have already been implemented in 14 Chinese Provinces mandating methanol blending, and are being implemented in additional Provinces.

• Small Mid-Boiler Market: In China, over 600,000 small to medium size industrial boilers consume approximately 700 million metric tons of coal per year or 18% of China's coal consumption. The opportunity to vastly improve environmental performance has motivated the Chinese government to phase out all coal-fired boilers with the capacity of 35 tonnes/hour or less by 2020, creating a corresponding conversion opportunity to methanol-fired boilers on the heels of currently converted boiler units which consume about 1 MTPA of methanol.

Gastech Insights: What monetisation opportunities can the methanol markets sector offer Canadian gas producers and what work needs to be done to ensure these opportunities are realised?
Mary Hemmingsen: Canada needs to realize the first-mover opportunity and accelerate aggressive efforts to capture new high value-add methanol markets in scale development. Leveraging our low-cost natural gas and advantaged gateway to a new growing clean Asian methanol economy, we need to crack the barrier of pipeline access and relentlessly focus our efforts to deliver a cost competitive advantage. Scale development and scale economics using between 1 to 2 bcf of gas would support at least two facilities of up to 28 MTPA of manufactured methanol and would capture a portion of the identified and looming methanol demand.

We need to act on the investment in related development already made in modularized construction and of interested host First Nations. This includes formalizing investments and the sharing of investment, costs and/or corridors for pipelines as well as providing various fiscal support arrangements and removing pipeline and other costs and delay barriers such as import duties and prolonged regulatory process, based on the high value-add for Western Canada and Canada as a whole.

We need to invest as a coordinated industry value chain and supply chain, relentlessly focused on cost competitiveness to be first to this new market. In doing so we can capture both a rapid step function increase in Asian methanol demand toward improved environmental performance and provide a supporting platform for other gas exports including Natural Gas Liquids (NGL) and LNG.

Gastech Insights: How can the industry harness the potential of liquid-rich gas successfully – allowing NGLs to turn from a hindrance to a help for Canadian shale producers?
Mary Hemmingsen: Recognizing the increasing "hotness" of liquid-rich production such as Montney gas, investment in pipeline corridors and support for co-development platforms, complemented by coordination in market development, is not only an opportunity but an imperative. Our Canadian governments and agencies, in partnership with focused industry players, can establish market entry and market penetration in supporting a cost competitive and timely development and manufacturing environment.

Gastech Insights: Why should industry players attend the Canada Gas and LNG Exhibition and Conference in May?
Mary Hemmingsen: The conference will bring together the players who are poised to inform and lead a new thrust for market access and development for our vast Western Canadian gas resources, and in doing so realize the opportunity of gas value-add export products to contribute to the trifecta of energy, economic and global environmental performance improvement.

The Canada Gas and LNG Exhibition and Conference on 14-16 May, will identify the opportunity, tackle the challenges and set the solutions for long-term gas monetisation in Canada. Hear Ms Hemmingsen speak along with many other industry experts, book your pass today.
Image courtesy of NW Innovation Works

The NW Innovation Works and how methanol instead of LNG facilitate and export Canadian stranded gas. The higher costs associated with exporting it and the effects it will have on the NW economy is detailed in the articles below.

BP and China sign methanol plants at Port of Kalama and Port Westward
BP and China create Northwest Innovation Works JV

The UK super major BP and China Academy of Sciences created a cascade of joint venture called Clean Energy Technology Company to run the Northwest Innovation Works joint venture, a newly formed company, to build and operate twin major greenfield methanol plants at Port of Kalama in Washington, and at Port Westward in Oregon, USA.

With a total capital expenditure of $3.6 billion, BP and China Academy of Sciences intend to use the gas-to-methanol conversion to facilitate the export of natural gas to China.

Methanol proposal arrived in Tacoma after extensive Inslee courtship
By Derrick Nunnally APRIL 09, 2016

A chart in the presentation's slide show described the Northwest's natural gas as a "stranded cheap resource." Another slide said it could become more profitable if converted to methanol for export than if exported as liquid natural gas.

Testimony of Paul N. Cicio
President
Industrial Energy Consumers of America

Excessive LNG exports significantly accelerate consumption of U.S. low-cost natural gas - damaging long-term manufacturing competitiveness and jobs.
Excessive LNG exports are not in the public interest and will increase the domestic price of natural gas and natural gas-fired electricity, reduce global competitiveness, reduce GDP, and impact middle class jobs.
Exporting LNG is a failed public policy. Consuming the natural gas in manufacturing creates eight times more middle class jobs.
Excessive LNG exports significantly accelerate consumption of low-cost natural gas – damaging long-term manufacturing competitiveness and jobs.
Natural gas is not a renewable resource and LNG exports significantly accelerate the consumption of
U.S. low-cost natural gas.

Pacific NW Consumers Will Pay More for Energy if LNG Exports Go Forward
Where does Spectra's Westcoast Energy pipeline go at the U.S. border?
July 25, 2014British Columbia, Canada, FERC, WashingtonJohn S. Quarterman
The combined Oregon LNG/Williams Expansion projects will force Pacific Northwest gas customers to outbid high-priced Asian markets for North American natural gas. The project will increase prices for every NW resident. Paul Cicio, President of the Industrial Energy Consumers of America, stated, "In the end, it's going to be every homeowner, every farmer buying fertilizer, and every manufacturer trying to create jobs who is going to be hurt by this."
Monetizing methanol Exporting natural gas in the form of methanol offers several advantages over the LNG pathway, argues an energy security expert.

Why Canada needs more pipelines FEBRUARY 13, 2019

In recent months, Canadian natural gas has been trading as low as one-third the price of U.S. gas, and sometimes close to one-tenth the price it could fetch in new markets, such as China, Japan, Korea and India.
For producers to realize better prices for natural gas they must diversify away from dependence on the U.S. market to areas where there's greater demand.

Rescue stranded gas assets with new markets, urges expert
B.C. has world-class natural gas reserves, but so does the U.S., which has gone from customer to competitor
By Nelson Bennett | March 29, 2016

Cheap gas from the Marcellus shale formation in New York state has been flooding into Eastern Canada, which was once supplied largely by the western provinces.

"That used to be almost all Canadian gas," said Dan Allan, executive vice-president of the Canadian Society for Unconventional Resources . "It's now being displaced by cheaper [U.S.] gas."

From 2007 to 2014, exports of Canadian natural gas to the U.S. declined 29%, according to Geoff Morrison, B.C. manager of operations for the Canadian Association of Petroleum Producers.

The Canadian Energy Research Institute estimates the flow of gas from the U.S. into Canada will double by 2027.

Thanks to the shale gas revolution, the Marcellus shale formation alone now produces more natural gas than all of Canada, Morrison said.
"We've been observing the U.S. [supplying gas to] markets that we traditionally serve, both in the States but also places like southern Ontario and Quebec," Morrison said. "Our biggest customer is now our biggest competitor, both in terms of North America [and] in terms of LNG."

But the U.S. isn't the only country with rich unconventional gas assets. The Montney Formation in northeastern B.C. is considered one of the richest in North America, due to its liquids.

And earlier this month, the National Energy Board updated estimates for the Liard Basin, which straddles B.C., the Yukon and the Northwest Territories. According to that estimate, B.C.'s share of the Liard has four times as much gas as previously estimated.

But without an export market in the form of an LNG industry, it's unlikely to see much development.

"We've got a big tank of gas up here and we've got limited customers," said Greg Bury, president of the Gas Processing Association Canada. "If we don't get to the coast, ultimately we are going to have stranded gas and we are going to stop building projects.

"It's happening every day as we speak. I have been intimately involved with so many project cancellations that it's ridiculous."

Porter suggested the North American public doesn't realize just how important the shale gas boom has been for the American economy.

"We estimate that more than half of all the jobs that have been created since the Great Recession ended were in energy, or related to energy in one way or another," he said.

Since energy is a huge part of any economy, cheap oil and gas – for both power and transportation – are a huge competitive advantage.

"This has allowed us in the U.S. to have a substantial energy cost advantage over pretty much every other country, except Canada," Porter said.

But both Canada and the U.S. are at a crossroads.
Because of the local environmental concerns that fracking poses, and concerns about the effect on climate change of burning natural gas, shale gas and LNG are getting a rough ride in the department of social licence and the office of public opinion.

But just as North American innovation led to the shale energy revolution, Porter said, it can also address the attendant environmental concerns.
"This opportunity is truly a game-changer," Porter said. "Right now it doesn't feel so good, because oil prices are down and gas prices are linked to oil. But over the long run, this downturn is stimulating another wave of innovation and efficiency and competitive advantage."

Far from thwarting renewable energy investments, natural gas could be a buttress, he said.
"We're going to need a lot of natural gas if we're going to make the transition to clean energy. Natural gas is a powerful tool we have to make this transition, because it's going to take decades to do it. In the process of using natural gas as a transitional fuel, it's going to also hold down the cost of the transition."

2018 Economic Report Series LEVERAGING OPPORTUNITIES: DIVERSIFYING CANADA'S OIL AND NATURAL GAS MARKETS

Canadian producers are currently faced with insuf¬cient takeaway capacity for both oil and natural gas. This in turn limits Canada's ability to serve existing domestic and U.S. markets, and prevents Canada from accessing emerging overseas markets.

Even more urgently, lack of infrastructure has caused discounted prices for Canadian oil and natural gas exports to the U.S. These price discounts cost Canadians billions of dollars every year. Canadians deserve fair market value for our natural resources.

The key to obtaining better value for our resources in global markets is to build new and improve existing infrastructure, so Canadian energy products can compete for emerging global markets. Even more urgently, lack of infrastructure has caused discounted prices for Canadian oil and natural gas exports to the U.S.
Canadian natural gas growth is limited by pipeline infrastructure bottlenecks and a lack of LNG export infrastructure, resulting in severely discounted prices for western Canadian natural gas in both domestic and U.S. market

Prices for natural gas have been persistently low for a decade, because supply has outstripped demand

This is a highly competitive market. In 2016, Wood Mackenzie conducted a competitiveness study for LNG,9 which showed that a Canadian facility could deliver LNG to northern Asia markets at around US$11 per million British thermal units (MMBtu). While not as competitive as U.S. Gulf Coast projects, Canadian projects were seen to be more competitive than Australian greenfield projects and Alaskan LNG. LEVERAGING OPPORTUN
Canadian pipeline projects currently in development – particularly TMEP – would provide producers with much-needed market access options and reduce reliance on the U.S. as Canada's single export market. In addition, the proposed Eagle Spirit Energy project would transport oil from Alberta and B.C. to a West Coast export facility.

Canada's Natural Gas Industry Really Needs LNG
For western Canada, too much supply, not enough demand, and worsening pipeline constraints have saddled the gas industry with "the lowest prices in the world," even in negative territory.

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Comment From: jim minick

10/06/20 @ 2:31 PM
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: Liisa Wale

10/06/20 @ 2:24 PM
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: Bill Adams

10/06/20 @ 1:59 PM
Please do not let this project happen. It would be an environmental train wreck in the making. According to Sightline Institute, a PNW environmental think-tank, its air pollution would be equivalent to 4.6 million tons of carbon dioxide each year or ...↓
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Comment From: MLou christ

10/06/20 @ 1:49 PM
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: Steve LACROIX

10/06/20 @ 1:23 PM
I am strongly opposed to the permitting of Kalama Manufacturing and Marine Export Facility. The proposed merit that it will displace coal plants in China is ludicrous. Just because one actor is slightly worse than ourselves does not have us coming ou...↓
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Comment From: Timothy Lewis

10/06/20 @ 12:45 PM
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: Stephen Anonymous

10/06/20 @ 12:28 PM
The proposed Kalama methanol plant would be a disaster for the health and well-being of Washingtonians. As we grapple with the impacts of climate change, with the entire state under hazardous amounts of smog for much of September, it is reckless to c...↓
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Comment From: Susan Haywood

10/06/20 @ 10:30 AM
Just say NO to the refinery in Kalama.
It is a climate catastrophe even before it gets to Washington state. Tar sands are spewing methane as we speak. Pipelines are leaking into water supplies. Oil trains explode---in fact one did here in Mosier, Oreg...↓
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Comment From: Bonnie McKinlay

10/06/20 @ 10:11 AM
To accept the proposal to advance the construction of the Kalama Manufacturing & Marine Export Facility at the dawn of human-caused climate disruption is unacceptable. I urge Dept of Ecology to reject this plan. We all are entrusted to care for this ...↓
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Comment From: Washington State Building & Co... (Mark Riker)

10/06/20 @ 8:30 AM
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Comment From: Donna Orr

10/06/20 @ 8:02 AM
I am a resident of Cowlitz County, not another state or country. I am an ordinary citizen that has watched with amazement at the persistent delays that are crushing each suggestion of economic recovery to our county. There is no "perfect "manufacturi...↓
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Comment From: Linda Leonard

10/06/20 @ 7:58 AM
The greatest crisis we face as a civilization is climate change which is driven by the burning of fossil fuels. We are at a tipping point; the warming of the planet is causing the accelerated melting of the Greenland and Antarctic ice sheets.

The eff...↓
1. The highest temperature ever recorded on earth in Death Valley during August 2020 was 130 degrees.
2. The worst wildfire season in history on the West Coast.
3. The East Coast is experiencing twice the number of tropical storms than normal.

The SSEIS analysis shows that current global greenhouse emissions for the state of Washington would increase substantially if this project were built. The increased pollution from the world's largest fracked gas to methanol refinery in the world, here in Kalama, would add 4.6 million tons of carbon dioxide to the atmosphere each year. This project's demand for fracked gas would exceed the consumption of the Northwest biggest cities combined.

Factor in the fracked gas transportation leakage rates, the usage of methanol being used to make plastics or used for fuel, Northwest Innovation Works' proposed refinery would jump to 9.4 million metric tons of greenhouse gases per year. This project would increase fracked gas demand, resulting in more well drilling, fracking and would require a larger capacity of gas, resulting in a new pipeline being needed, locking in future fossil fuel usage for the next 40 years.

Is this what we want for Washington state or do we need to move toward a low carbon future?

Governor Inslee's Evergreen Action Plan is the clean energy needed. This plan is built upon 5 key principles.
1. Power the economy with 100% clean energy.
2. Invest in good jobs, infrastructure, Industry and Innovation.
3. Build greater Justice and Economic Inclusion.
4. End Fossil fuel Giveaways
5. Mobilizing Global Action

We have a global responsibility to phase out fossil fuel reliance in favor of clean energy.

As a resident of Kalama, I am concerned for the future of Kalama, the consequences of this massive fracked gas to methanol refinery will have on the health and safety of the citizens. We all deserve the right to clean air and water and to protect the Columbia River.

The evidence in the SSEIS demonstrates that the Department of Ecology must deny NWIW the permit needed for this project to proceed. We cannot keep building fossil fuel export infrastructures, the dangers of climate change are real.
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Comment From: Coquette Shapiro

10/06/20 @ 7:56 AM
All species are important and must be protected. NO methanol refinery. We must not upset the delicate balance of climate, water, air and the entire web of life!
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