August 14, 2013 Nicole Dandurand State of Louisiana Department of Natural Resources Office of Coastal Management Post Office

Box 44487 Baton Rouge, LA 70804-4487 nicole.dandurand@la.gov RE: RAM Terminals, LLC Coastal Use Permit Application CUP Number: P20120190

Thank you for providing the public an opportunity to review and comment on RAM Terminals, LLCs (RAM Terminals) Coastal Use Permit Application to construct and operate a coal terminal facility as a use of state concern. These comments are submitted on behalf of the Gulf Restoration Network (GRN), the Louisiana Environmental Action Network (LEAN), Public Citizen, the Lower Mississippi Riverkeeper, and Delta Chapter of the Sierra Club. GRN is a network of thousands of individual citizens and local, regional, and national environmental and public interest groups dedicated to uniting and empowering people to protect and restore the natural resources of the Gulf Region. The Sierra Clubs Delta Chapter has over 2,850 members in Louisiana, and is dedicated to protecting and restoring the quality of Louisianas natural and human environment. LEAN is a statewide network of more than 100 member groups and 1700+ individual members, all devoted to the creation and maintenance of a cleaner and healthier environment for all of the inhabitants of this state. Public Citizen Texas mission is to be the most effective advocates for the environment and its citizens against 1

corporate and government irresponsibility. As part of the Waterkeeper Alliance, the Lower Mississippi Riverkeepers (LMRK) goal is to champion clean water and the communities which it serves. LMRK serves to energize current activists to participate in environmental decisions, educate the public and government leaders about environmental challenges and economic opportunities regarding the Mississippi River and how reduced water pollution benefits all of us. We submit these comments in response to the Department of Natural Resources public notice for CUP 20120190 RAM Terminals Coal Export Facility on the Mississippi River (the Facility) in Plaquemines Parish, and ask that this permit be denied. We reserve the right to rely on all public comments submitted, request a written response to our comments, and request written notification when any action is taken on this Draft Permit (issuance, denial, remand, etc.). In particular, we incorporate by reference the comment letters submitted by the Tulane Environmental Law Clinic on behalf of the Christian Ministers Missionary Baptist Association of Plaquemines, Inc., Ms. Joyce Cornin, and Ms. Velma Davis. We also incorporate the concerns expressed in our previous comment letter regarding this permit, which was submitted on May 15th, 2012 and is attached as Exhibit A to this letter. I. LDNR should deny the coastal use permit as the RAM Terminal is in conflict and inconsistent with the Myrtle Grove Sediment Diversion.

The proposed coal/petroleum coke barging facility and associated rail loop is located south of the Alliance Refinery and north of Ironton, just above river mile 60, on the site of the LCA Medium Diversion at Myrtle Grove with Dedicated Dredging ecosystem restoration project (the Sediment Diversion). The project has been authorized by WRDA 2007 to restore coastal wetlands in the central Barataria Basin. This project is the first diversion designed to build wetlands by transferring coarse sediments via gravity from the Mississippi river, and has been identified as one of five critical near-term coastal restoration projects in the state master plan. Specifically, this diversion has been designed to maximize sediment delivery from the local sand bed upriver from RM 60. As outlined in Exhibit A and below, the Facility would directly conflict with the Sediment Diversion and is inconsistent with Louisianas Comprehensive Management Plan for a Sustainable Coast (state master plan). The high potential for conflict between the proposed terminal and the Sediment Diversion has been recognized by the U.S. Environmental Protection Agency (EPA), the National Marine Fisheries Service (NMFS), and the Coastal Protection and Restoration Authority of Louisiana (CPRA).1 On February 7, 2013, the Army Corps of Engineers withdrew the Clean Water Act 404 permit application for this proposal, citing a failure by RAM Terminals, LLC to provide needed information for processing the permit. The Facility has the potential to negatively impact the success of the Sediment Diversion by polluting the water going into the wetlands. RAM Terminals, LLC plans to
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See attached, Exhibits B, C, and D.

export up to 10 million tons of coal and/or petroleum coke each year, which will be stored in uncovered piles on the facility and will be loaded and unloaded using uncovered conveyors. According to EPA documents, coal pile runoff may contain high concentrations of copper, mercury, iron, nickel and other toxic constituents.2 At similar coal terminals along the lower Mississippi River, coal dust and coal chunks are routinely deposited into the surrounding water bodies and environment as coal is blown off coal piles or conveyors, coal is spilled during loading and unloading, and coal sticks to conveyor belts and falls into the surrounding water.3 This photo shows a build-up of coal sediment on the river bank south of the United Bulk Terminal, which is exports over 11 million tons of coal each year near Davant, LA:

Coal terminals in other areas of the country that are designed and operated similar to the proposed RAM Terminal struggle to contain offsite emissions of coal dust, coal chunks, and contaminated stormwater and wastewater, as seen in Roda and Newport News, Virginia, Mobile, Alabama, and Floyd County, Kentucky.4 As the applicant does not plan to
EPA. Steam Electric Power Generating Point Source Category: Final Detailed Study Report. EPA 821-R-09008. pp. 3-22 3-23, available at http://water.epa.gov/scitech/wastetech/guide/steamelectric/upload/Steam-Electric_Detailed-Study-Report_2009.pdf 3 See attached, Exhibit E. 4 See, e.g., http://www2.tricities.com/news/2010/mar/31/pollution_board_takes_action_on_coal_dust_complain-ar235582/; http://articles.dailypress.com/2011-08-01/news/dp-nws-coal-dust-folo20110801_1_weathersolve-coal-dust-wind-fence; http://www.conservationalabama.org/index.asp?Type=B_PR&SEC={B8BDE2CD-75C7-49F3-B6132ABEBFB938E1}&DE={7DE5A4C3-40E5-4C26-B650-E03586EFE1D0}; and http://www.floydcountytimes.com/view/full_story/1415092/article-Goble-Roberts-residents-sue-overcoal-dust.
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implement the best available control technology to prevent emissions of fugitive dust and other coal fragments (which would require completely enclosing the facility, including conveyors, storage piles, and loading and unloading equipment), the RAM Terminal will invariably contaminate the newly restored wetlands in the Barataria Basin with coal, petroleum coke, heavy metals, and other toxic constituents of coal and petroleum coke. The mere presence of coal dust has been shown to cause ecological harm. In South Africa, for example, a 2004 study found that coal dust from the Richards Bay Coal Terminal found that coal harms local mangrove trees and related ecosystems by impairing the ability of the trees to photosynthesize. The researchers noted: [coal] dust on the undersurface of leaves is not removed by wind, rain, or even physical washing. The undersurface of the leaves, as well as the rough surfaces of twigs, branches and trunk, tend to accumulate dust and appear black.5 A 2006 study in British Columbia found that the steady accumulation of coal sediment on the sea floor could harm the flora and fauna living on the sea bottom, as oxidizing coal particles reduce the oxygen available.6 Coal and petroleum coke sediment can be especially damaging to marsh and wetland plants, as coal and petroleum coke wastes contain sulfides that can hamper the metabolism of the roots of marsh plants. These roots are essential for the shear strength of the marsh, and the success of the Sediment Diversion depends on the health of the newly restored grasses and other marsh plants, which will protect the fragile wetlands from storm surges. The RAM Terminal is therefore inconsistent with the state master plan, as it will deposit toxic coal and petroleum sediment directly into the Sediment Diversion and hamper the restoration process. Furthermore, coal piles in this region routinely flood during storm events and hurricanes, and can deposit large amounts of toxic and contaminated waters into the surrounding environment.7 There is nothing in the record to demonstrate that the Facility has been designed to withstand the frequent flood and hurricane events in the region and/or prevent pollution releases during storms. Rising sea levels and regional subsidence will only exacerbate these risks, and expose surrounding communities and fragile wetlands to more toxic effluent following tropical storms and hurricanes. 8 In fact, recent scientific analysis has found that Southern Louisiana faces the highest rate of sea level rise in the nation.9 Placing the RAM Terminal at this flood-prone site therefore presents an obvious
G. Naidoo, D. Chirkoot. The effects of coal dust on photosynthetic performance of the mangrove, Avicennia marina in Richards Bay, South Africa, Environmental Pollution, Volume 127, Issue 3, February2004, Pages 359366. 6 Ryan Johnson, R.M. Bustin. Coal dust dispersal around a marine coal terminal (19771999), British Columbia: The fate of coal dust in the marine environment. International Journal of Coal Geology, Volume 68, Issues 12, 1 August 2006, Pages 5769. 7 See http://greenpeaceblogs.org/2012/09/06/photos-pollution-from-flooded-coal-export-terminal-inlouisiana/ 8 http://www.magazine.noaa.gov/stories/mag101.htm 9 http://thelensnola.org/2013/02/21/new-research-louisiana-coast-faces-highest-rate-of-sea-level-rise-onthe-planet/
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and significant environmental threat to the success of the Sediment Diversion, a project whose goal is to rebuild and restore Louisianas disappearing coastal wetlands in the face of rapid subsidence, climate disruption, and sea level rise. Finally, the Sediment Diversion and the Facility may be in physical conflict with one another. As noted by CPRA, the location and size of the diversion may interfere with barge fleeting and the facilitys operations, as it will be diverting up to 125,000 cubic feet per second at this point in the river.10 This may destabilize the Facilitys dock; additionally, if the barges become unstable and break free from moorings due to unstable currents, they could damage the levees and other structures associated with the Sediment Diversion. This image, created by LDNR, clearly shows the potential conflict between the diversion channel and the fleeted barges associated with the terminal:

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See Exhibit D.

Recent comments from HDR Engineering, the contractor in charge of the planning and design of the Sediment Diversion, noted that the barge fleeting for the CHS grain terminal will have to be re-located.11 If the existing barge fleeting at this location is inconsistent with the Sediment Diversion, a ship terminal is more so. The EPA, NMFS, and CPRA have acknowledged that the only way to reconcile the two projects without drastically changing the size, location, or proposed operation of the coal terminal may be to alter the design, size, or operation of the Sediment Diversion, and have expressed their objection to this prospect. As noted by EPA: In particular, EPA is concerned that permitting the coal facility as currently proposed could force the Corps to use a diversion alignment which would connect to the Mississippi River at a point where suspended sediment loads are substantially lower than would be the case with the Corps currently recommended diversion alignment. Moreover, while there may be an alternative for the Myrtle Grove Diversion, if this alternative diversion location would result in reduced environmental benefits, cost more to build, and/or result in delays in project implementation, the project should not be built.12 Indeed, notes from a meeting between LDNR and the applicant in June of 2012 indicate that RAM Terminals intended to request that CPRA move the diversion site farther south on the river.13 Changing the diversion site would ignore CPRAs careful selection of the present diversion location based on an intensive Mississippi River data collection and modeling effort that identified river mile 60.7 above Heads of Pass to optimize sediment capture from the river.14 State law requires that the LDNR shall ensure that the activity for which the application is being made is consistent with the states master plan for integrated coastal protection. No activity which is not consistent with the plan shall be granted a coastal use permit.15 Furthermore, DNR is duty-bound to demonstrate that it has properly exercised the discretion vested in it by making basic findings supported by evidence and ultimate findings that flow rationally from the basic findings; and it must articulate a rational connection between the facts found and the order, or in this case, the permit issued.16 On January 23, 2008, Louisiana Governor Bobby Jindal gave even greater weight to the recommendations laid out in the 2007 Master Plan by issuing Executive Order No. BJ 2008-7 (Executive Order). This Executive Order requires that all state agencies administer their regulatory practices, programs, contracts, grants, and all other functions
Monday, August 12th MGSD meeting in Luling, LA. See Exhibit B (emphasis added). 13 Exhibit F (RAM is coordinating with CPRA and will request that the diversion be shifted slightly south.). 14 Exhibit D. 15 LA R.S. 49:214.30 (A)(2). 16 In re Oil & Gas Exploration, Development, & Production Facilities, Permit, --- So.3d ----, 2011 WL 2297790; La. App. 1 Cir. 2011; In re Rubicon, Inc., 670 So. 2d 475, 483, 95-0108 (La. App. 1 Cir. 2/14/96) (citing Save Ourselves, 452 So. 2d 1159-60).
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vested in them in a manner consistent with the Master Plan and public interest to the maximum extent possible.17 The Executive Order, in addition to ordering all state agencies to comply with the Master Plan, asserts that state agencies must function in a manner that recognizes the vital importance of expediting hurricane and coastal protection and ensuring sustainable practices in our coastal zone. Here, nothing in the record supports the conclusion that the project is consistent with the state master plan, and the record in fact demonstrates that the coal terminal: (1) would likely contaminate the Sediment Diversion and surrounding communities with offsite emissions during normal operations; (2) would be vulnerable to releasing large amounts of coal, petroleum coke, and coalcontaminated waters during storm and hurricane events and has not been designed to withstand these storms; and (3) is in physical conflict with the diversion channel.18 Therefore, the LDNR should deny the permit. II. The applicant has failed to respond to comments, perform an alternatives analysis, demonstrate the public need for this project, or demonstrate consistency with the state master plan.

After the CPRA found that it was probable that the Sediment Diversion and the Facility cannot exist together,19 LDNR directed the applicant to work with CPRA and obtain a no objection letter stating that the project was consistent with the state master plan before scheduling a hearing. 20 LNDR also requested that the applicant provide a response to all public comments. There is no indication that RAM Terminals has acquired a no objection letter from CPRA. A. RAM Terminals did not respond to comments

RAM Terminals, LLC submitted a letter on July 2, 2012 that the applicant alleged was a response to the public comments submitted during the public comment period for this permit.21 However, the letter failed entirely to analyze or discuss the multiple issues addressed by the public comments submitted by Sierra Club, GRN, LEAN or any of the other organizations and citizens that submitted comments on this permit. The letter merely recites the various permits and authorizations that the facility must obtain before it begins operating and affirms its intention to acquire those permits, without any discussion or
17 Exec. Order No. BJ 2008-7, available at http://gov.louisiana.gov/assets/docs/OfficialDocuments/2008EO7SustainableCoast.pdf. 18 In addition to the conflict with the Sediment Diversion, there are other aspects of the project that are in conflict with the state master plan and Executive Order BJ 2008-7, as discussed in our initial comments. See Exhibit A. 19 Exhibit D. 20 Exhibit F. 21 See attached, Exhibit G.

analysis of the many issues addressed by the public and the federal agencies. This response is plainly inadequate, and RAM Terminals has failed to respond to public comments. B. RAM Terminals has failed to analyze alternatives to the project

A particularly glaring example of the applicants failure to respond to comments was the lack of any information on alternatives to the proposed terminal. The Louisiana First Circuit held in In re Rubicon, Inc. that LDEQ, a similar agency with the power of a public trustee, must consider whether there are alternative projects or alternative sites or mitigating measures that would offer more protection to the environment than the proposed project without unduly curtailing non-environmental benefits to the extent applicable. Rubicon, 670 So.2d 475, 483 (La. App. 1 Cir.1996). Neither the applicants response nor any of the application materials discuss alternate locations or alternate facility designs that would mitigate the Facilitys environmental impacts. The applicant has failed to demonstrate that its proposal is the least environmentally damaging alternative, or that there are no other alternative locations that could avoid the present conflicts with the Sediment Diversion. RAM Terminals, also fails to analyze or discuss alternatives that might mitigate public health impacts to surrounding communities. During the public comment period, multiple local organizations and local residents outlined their concerns about coal dust and diesel pollution being emitted into their communities from the coal terminal. This area is already overburdened by industrial pollution from the existing coal terminals, oil refineries, and chemical facilities. In particular, the RAM Terminal would leave the small community of Ironton surrounded by three coal terminals, and oil refinery, and a grain elevator, all of which emit particulate matter and air pollution that is both a nuisance and a serious health threat. There is no discussion of these issues in either the application materials or the response to comments provided by the applicant, and no discussion of alternative locations or facility designs that would mitigate or avoid these impacts. C. RAM Terminals has failed to demonstrate any public need for the proposed terminal.

RAM Terminals, LLC has not demonstrated the public need for the RAM Terminal to be located on this site, which the same location as a critical wetland restoration project and is less than five miles north of two existing coal terminals that are both expanding their capacity. As numerous investment analysts have noted, the international market for coal has eroded over the last year, and U.S. producers in particular will have difficulty competing with other players on the international market for exported coal.22 Goldman Sachs recently stated that the prospect of weaker demand growth (we believe seaborne demand could peak in 2020) and seaborne prices near marginal production costs suggest
http://www.bloomberg.com/news/2013-08-05/coal-at-risk-as-global-lenders-drop-financing-onclimate.html; https://healthygulf.org/201307222097/blog/healthy-waters-/-dead-zone/the-quickest-routeto-china-is-throughthe-gulf-of-mexico
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that most thermal coal growth projects will struggle to earn a positive return for their owners.23 With the current oversupply in the global coal market, and with two very large coal terminals operating less than five miles downriver, it is difficult to see how RAM Terminals, LLC can demonstrate that the market would support another coal terminal on the lower Mississippi River.24 D. RAM Terminals has failed to demonstrate consistency with the state master plan

As stated above, there is no evidence that the applicant has acquired a no objection letter from CPRA, and it has failed to demonstrate that the project is consistent with the state master plan. The applicant has not altered the proposed design or operation of the terminal to account for the identified inconsistencies with the Sediment Diversion, and has instead asked that the design of the Sediment Diversion be altered to accommodate the coal terminal. Given that none of the inconsistency problems identified by EPA, NMFS, CPRA, or the public have been addressed or resolved, LDNR should deny the permit. III. CPRAs Draft Permit Conditions are legally inadequate and do not prove that the RAM Terminal is consistent with the state master plan. CPRA did provide a set of draft permit conditions in an attempt to demonstrate what conditions would be necessary before CPRA would sign off on the Facility.25 We do not believe that these conditions are sufficient to demonstrate consistency with the state master plan, and are therefore not legally adequate under the applicable case law, statutes, and regulations. First, the draft conditions do not alter the location, design, or operation of the proposed terminal to resolve the potential conflicts with the Sediment Diversion and ensure consistency with the state master plan. Indeed, the draft conditions place the onus for determining and maintaining consistency on the applicant, rather than the agency. Draft Condition 6 requires the applicant to analyze and disclose the impacts of the coal terminal on the Sediment Diversion, and accept any conditions that the state deems necessary after such analysis is complete (presumably after LDNR grants the coastal use permit). Draft Condition 7 states that applicant agrees that it will not operate its facility in a manner that will adversely affect in any way the efficient and effective operation of the Sediment Diversion. However, under state law, it is the duty of LDNR to ensure consistency with the state master plan, and the statute explicitly states that no activity which is not consistent with

23 http://grist.org/climate-energy/goldman-sachs-says-coal-export-terminals-are-a-bad-investment/ (emphasis added). 24 Indeed, Armstrong Coal, which is the parent company of RAM Terminals, LLC, has failed to secure investors for its proposed IPO, which demonstrates that there is little investor interest in this company or its business model. http://www.nasdaq.com/article/coal-producer-armstrong-energy-withdraws-ipo-cm261211 25 Exhibit H.

the plan shall be granted a coastal use permit.26 LDNR may not avoid its duty to find consistency with the state master plan by delegating its authority to the applicant. In Save Ourselves, Inc., v. Louisiana Envtl. Control Commn, 452 So. 2d 1152, 1157 (La. 1984), the Court found that Article IX, Section 1 of the Louisiana Constitution imposes a reasonableness requirement on agencies to determine that adverse environmental impacts have been minimized or avoided as much as possible consistently with the public welfare. The Court goes on to say, the rights of the public must receive active and affirmative protection at the hands of the [agency].27 Draft Permit Condition 6 would allow the agency to grant a permit before performing any of the required analysis to ensure that environmental impacts have been minimized or avoided and that consistency with the state master plan has been achieved, passively abdicating its authority. This condition directs the financially motivated applicant to perform the required analysis and reach its own conclusions regarding consistency. This violates the Public Trust duty placed on the Agency by the Louisiana Constitution, in addition to violating the plain language of the Louisiana Coastal Zone Management Program. It is the responsibility and legal duty of LDNR to perform the required environmental analysis prior to issuing the permit. The rights of the public to a safe and healthy environment must receive active and affirmative protection at the hands of LDNR, and the agency may not legally avoid these responsibilities through permit conditions. The Draft Permit Conditions are also in violation of applicable case law. In an analogous situation, the Louisiana Court of Appeals First Circuit found that the LDEQ violated the statute governing hazardous waste disposal when they placed a condition on the permit requiring the applicant to merely comply with the requirements of that governing statute before the facility became operational.28 Draft Condition 7, which directs the project proponent to avoid any adverse impacts to the Sediment Diversion, is essentially a mere restatement of the applicable law, as the Sediment Diversion is an essential part of the state master plan and the executive order requires consistency with that plan. LDNR may not grant a coastal use permit to RAM Terminals which contains permit conditions that require the applicant to merely comply with the requirements of the Coastal Zone Management Program and the state master plan, and cannot legally issue a permit unless the agency has demonstrated in the record that the permitted facility will be consistent with the state master plan. Furthermore, even if the Draft Conditions included design and/or operations restrictions that were sufficient to avoid adverse impacts to the Sediment Diversion and ensure overall consistency with the state master plan (which they dont), there are critical conditions that are missing from CPRAs initial draft. First, any permit issued by the agency for this terminal should require that the RAM Terminals demonstrate adequate third-party insurance or bonding to cover any damage to the Sediment Diversion from the Facilitys
LA R.S. 49:214.30 (A)(2). Id. 28 See In re Bell Co., LLC, 809 So.2d 225, 245 (La. App. 1 Cir. 2001)
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construction or operation. This bond or insurance should also be sufficient to cover any costs associated with removing the facility or any structures associated with the facility and restoring the area to its previous condition, should it become clear that there is no way for the coal terminal and the Sediment Diversion to co-exist. This type of condition is explicitly contemplated by the applicable regulations. Louisiana Administrative Code, Title 43, Chapter 7, Subchapter C covering permit conditions provides that the agency may require an acceptable surety bond in an appropriate amount to ensure adjustment, alteration, or removal should the permitting body determine it necessary.29 Recent financial documents and reporting have demonstrated that RAM Terminals parent company, Armstrong Coal, has experienced large profit losses and serious financial difficulties very recently, with profits decreasing rapidly as debt nearly doubled.30 Although Armstrong Coal hoped to finalize going public in the first quarter of 2012,31 for reasons the company did not specify, it withdrew its IPO in July 2013.32 Given the financial instability of its parent company, RAM Terminals should not be allowed to self-bond. A vast amount of federal and state money and resources are being invested in the development and implementation of the Sediment Diversion (estimated at almost $300,000,000.00), and LDNR should protect this investment in the states important wetland resources with a condition requiring adequate third-party insurance or bonding, should it choose to issue a permit. Finally, any permit issued by LDNR should include a condition explicitly stating that the planned design, construction, and operation of the Sediment Diversion will not be altered to accommodate the coal terminal. As stated above and as outlined by CPRA, the location and design of the diversion channel has been carefully selected and planned to maximize wetland restoration and to ensure the success of the project. The location of the channel and the proposed operation of the diversion should not be altered, unless it is determined through subsequent scientific study that there is another design that will almost certainly result in a higher yield and greater success for the wetland project. RAM Terminals must not be allowed to alter the design of the Sediment Diversion for their own purposes. III. Conclusion

LDNR should deny the coastal use permit for the Facility proposed by RAM Terminals, LLC, as it is inconsistent with the state master plan. LDNR cannot approve this permit and follow the executive order on consistency. RAM Terminals, LLC has failed to respond to comments, perform an alternatives analysis, demonstrate the public need for this project, or demonstrate consistency with the state master plan. CPRAs Draft
LAC, Title 43, Chapter 7, Subchapter C, 723.C.9.iv Armstrong Energys March 2012 filing with the Securities and Exchange Commission (SEC) in anticipation of going public revealed a downward trend for the company. Its audited net earnings decreased each year from a high of $10.4 million in 2009 to $4.3 million in 2011. Its total debt nearly doubled from 2010 to 2011, from $139.8 million to $244.8 million. http://www.nasdaq.com/markets/ipos/filing.ashx?filingid=8262577 31 http://www.coalage.com/index.php/news/news/1735-armstrong-will-go-public.html 32 http://www.nasdaq.com/article/coal-producer-armstrong-energy-withdraws-ipo-cm261211
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Conditions are inadequate to fulfill the legal duties of the agency or ensure consistency with the state master plan. Sincerely,

Scott Eustis, M.S., Coastal Wetland Specialist, Gulf Restoration Network

Haywood Martin, Chair, Delta Chapter of the Sierra Club

Marylee Orr, Executive Director, Louisiana Environmental Action Network

Paul Orr, Riverkeeper, Lower Mississippi Riverkeeper

Thomas Smitty Smith, Director, Texas Office, Public Citizen

Cc: Karl Morgan, Administrator, Permits and Mitigation Division Garret Graves, Chair, Coastal Protection and Restoration Authority

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