Submission Number: MBTL-SEPA-DEIS-0002447 

Received: 6/10/2016 12:00:21 PM
Commenter: Rick Curtsinger
Organization: Cloud Peak Energy
State: Colorado

Agency: Cowlitz County and the Washington Department of Ecology
Initiative: Millennium Bulk-Terminals Longview SEPA DEIS
Attachments:
MBTL-SEPA-DEIS-0002447-100938.pdf Size = 306 KB
MBTL-SEPA-DEIS-0002447-100939.pdf Size = 4327 KB
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Submission Text
To Whom It May Concern: Introduction to Cloud Peak Energy, Its Throughput Option at MBT and Experience as a Leading Supplier to Asian Utilities Cloud Peak Energy Inc. (“CPE”) is headquartered in Wyoming and is one of the largest U.S. coal producers, with three owned and operated award-winning surface mines located in the Powder River Basin (“PRB”) in Wyoming and Montana. In 2015, CPE paid approximately $303 million in taxes, royalties and other payments to the federal and local governments, while incurring a net loss for 2015 of $204 million. CPE is widely recognized for its exemplary performance in its safety, reclamation, and other environmental programs, and is a sustainable fuel supplier for approximately three percent of the nation’s electricity. CPE’s approximately 1,500 employees mine low sulfur, sub-bituminous coal and provide logistics supply services. In 2015, CPE shipped approximately 75 million tons from its three mines to customers located throughout the U.S. and around the world. CPE also owns rights to substantial undeveloped coal and complimentary surface assets in the Northern PRB. CPE has a throughput option agreement for up to 7.7 million tons of capacity per year upon completion of the Millennium Bulk Terminals (“MBT”). CPE has been the largest single exporter in recent years of low sulfur coal from the PRB to East Asian countries that have included, among others, Japan, South Korea, and Taiwan. PRB coal is supplied to Asian countries as a swing supplier depending on the pricing environment, offsetting coal that would otherwise be purchased by those countries from alternative coal basins. As a result of being a swing supplier and depressed seaborne coal prices, CPE is not currently exporting coal to Asia. Flawed Assumptions in Draft EIS As a leading coal industry participant with experience and expertise supplying Asian electric utilities, CPE would like to offer comments on the flawed and inaccurate assumptions included in draft Environmental Impact Statement (“EIS”) for MBT regarding several issues including alleged CO2 emissions levels associated with potential coal exports from MBT. Specifically, as discussed below: Coal is incorrectly identified in the DEIS as a “hazardous material”. There is no regulatory basis for this designation and any such reference to coal in the DEIS must be removed or corrected. Regardless of whether MBT is constructed or how may tons of PRB coal may become available through MBT, Asian countries are continuing to build modern, efficient, and clean-burning coal-fired electric generating plants to provide reliable, affordable, safe, and diverse sources of power to their growing economies and to provide their growing populations with access to modern and healthy lifestyles afforded by low-cost power. Even at full capacity, coal shipped through MBT to Asian countries would be immaterial by any standard compared to the vast overall coal demand of those countries. Any notion, as erroneously included in the draft EIS, that coal shipped through MBT would somehow increase overall coal burn by Asian utilities and associated emissions is baseless and not supported by the facts. To the extent PRB coal is shipped through MBT to Asian countries, it would replace, not increase, coal that would otherwise be supplied by alternative coal basins. CPE’s PRB coal would compete primarily against lower quality Indonesian sub-bituminous and lignite coal. Given logistical economics, PRB coal would first displace Indonesia in the North Pacific countries of Japan and South Korea. Since higher heat content coal presents lower Greenhouse Gas emissions (“GHGE”) than lower heat content coals, the introduction of PRB coal for Asian customers would raise the overall average quality of coal and result in a net reduction of GHGE. Please see the attached .PDF documents with CPE's full comments and supporting evidence.