Submission Number: UBR-DEIS-00401 -- Oral Comment at Public Meeting 

Received: 12/3/2020 12:00:00 AM
Commenter: Malin Moench
Organization: Utah Physicians for a Healthy Environment

Agency: STB
Initiative: Uinta Basin Railway EIS
Attachments: No Attachments
Submission Text
Okay, can you hear me?


So that last name is a German name I don't even know how to pronounce, but it's Malin
Moench in America.

I am a lawyer and an economist.· And I am speaking for Utah Physicians for a Healthy Environment.

My main point is that the analysis of the No-Action Alternative in this draft EIS is woefully
inadequate.· This EIS confines itself to analyzing the environmental impact of building or not building the Uinta Basin Railway itself, while ignoring the expected tripling or quadrupling of oil and gas production that its proponents say it will trigger.· This is like doing risk analysis for the Titanic asking whether the dance band will play or not play while ignoring that the ship is steaming toward a looming iceberg.

In this case, the looming iceberg is the EPA's National Ambient air quality 8-hour standard for ozone.· The Uinta Basin is already a nonattainment area for ozone, often reaching concentrations in winter that exceed peak 8-hour levels in the Los Angeles Basin.

The 2014 Uinta Basin winter ozone studies point out that these high concentrations of ozone form when VOCs and nitrous oxide are trapped in pools of cold air and are exposed to ultra violet light reflected off snow.· These studies point out that the oil and gas operations are responsible for 99 percent of VOC emissions in the basin and nearly 60 percent of nitrous oxide emissions.

They say that the only way to bring the basin there into compliance with the clear act ozone
standard is to cut down on the ozone precursors.· Even though the basin is a ozone nonattainment area, the BLM has already approved leases that allow the basin two main oil and gas operators, Encana and Crescent Point, to double their fueling and production levels.· This railway is expected to result in another doubling of oil and gas production beyond those.· The cumulative effect will be a quadrupling of production and logically of ozone precursor emissions.· The Biden-led EPA can be expected to get back to enforcing the Clean Air Act after a four-year hiatus.· It will require any oil and gas expansion projects to get nonattainment resource review permits under an EPA state implementation plan.


NEPA requires of an EIS to analyze indirect and not just direct impacts of a project on a region's airshed.· It also requires an EIS to analyze cumulative effect of a project, not just the isolated impact.· And this EIS doesn't do either.

If it had analyzed the indirect and cumulative effect of the Uinta Basin Railway on the
basin's ozone levels, it would show that it would make compliance for the 8-hour ozone standard impossible going forward.· Its failure to undertake such an analysis makes it legally infirm.· And that concludes my statement.


Okay, did that succeed?


I thought the point about what would you get if you did an alternative investment of a
billion-and-a-half dollars was a very interesting point.

I have an economics degree, and one of the things that I have learned studying that subject is that the employment impact of low carbon energy swamps the employment impact of carbon-based energy.· It's -- the international monetary funded study of energy costs in the United States.· And their study concluded that if you spend a million dollars buying energy in a year, you could support 1.9 permanent jobs.· If you spent that same million dollars on wind-powered energy, you would support 5 jobs annually.· If you spent that million dollars on solar, you would support 7 permanent jobs.

So, if you were to spend that $1.5 billion on massive solar farms, which the Uinta Basin is
excellently suited for, could you have triple or more the employment impact on the people in the basin.· And it wouldn't be adding to their pollution problems.· It wouldn't be ruining the health of the people who live there.· And it would have had higher pay and more stable jobs.· It wouldn't be this boom-and-bust cycle of what has been plaguing the Uinta Basin's economy for the last 40 years.

That's all I want to say.