Michael F. Ford November
11, 2011
1956 Fashion Avenue
Long Beach, CA 90810
Chris Cannon, Director of Environmental Management
Port of Los Angeles
425 South Palos Verdes Street
San Pedro, CA 90731
RE: Southern
California International Gateway (SCIG) Project
Draft Environmental Impact Report
(DEIR)
Dear Sir:
During the November 10, 2011 SCIG Public Hearing on the
above project DEIR, several “issues” were raised concerning health risks and so
called “zero emissions technology”.
I respect neighbors who oppose the project because they do
not want change in the neighborhood we live in.
They have that right, whether I agree with them or not.
The positions I oppose are those that through honest
misunderstanding; failure to read the executive summary of the DEIR, or
deliberate deception, seek to stall or kill this project for ulterior purposes.
Concern was expressed that the project is not using Linear
Synchronous Motor (LSM) or Linear Inductive Motor (LIM) technologies, which
were claimed to be cleaner, more efficient, safer modes than diesel powered locomotives.
I spent the rest of the evening on the 10th, and
the better part of November 11th researching these claims. I studied
the General Atomics (in partnership with others) systems; “Zero Emissions”
Electric Container Moving System for the Ports of Long Beach / Los Angeles LSM
Technology Program presentation to the California Energy Commission April 27,
2009 (ITSC; AECOM, General Atomics,
MacQuarie Bank, 2009) ;and the same firms “Zero Emissions”
Propulsion on Standard Railway / Roadway Infrastructure presentation for
GreenTech Forum August 3-4, 2009 (Pasadena Convention Center seminar).
Based on the above, the following CRITICAL observations are
made:
·
Not one maglev project in operation today
includes heavy container transport.
·
Every system in operation today is some form of light
rail people mover.
·
ALL cost, environmental impact and efficiency
estimations appear to be for personnel movement systems operating under optimal
conditions, or circumstances that have NO RELEVANCE to container movement
costs, environmental impact or practicality.
·
The most ‘famous’ maglev technology developer in
America appears to be General Atomics.
They are studying container movers in San Diego, but have not
(reportedly) gone beyond the prototype experimental single TEU mover. It is not ready for “prime time” commercial
use.
·
General Atomics has envisioned hybrid
Maglev/Rail movers that move individual units one at a time via remote or
on-board guidance. This appeared to have
the greatest use potential in the current POLA / POLB environment, but has huge
downside risks that I submit; make it a completely unusable system here.
·
MagLev systems operating over the 4 miles to
SCIG would necessarily operate under the LEAST rather than optimal
conditions. It is unlikely they could
ever achieve ‘lift off’ speed (20 to 50 mph for commuter trains-unknown for
heavy transport trains). They would
instead operate under highest drag conditions for the entire route!
·
All environmental analyses for Maglevs are based
on optimal condition commuter trains that are from 30% to 40% LIGHTER than
normal light rail commuter trains. Inverse results exist when weight is
increased. The magnitude of negative net results for a freight train is simply
not published online, if it exists at all.
·
We don’t even know if the so called Bechtel
Formula is applicable where such a magnitude of difference exists.
·
The ‘East Yard Communities for Environmental
Justice put out a flyer in late August, 2011 claiming one-million (more)
containers will go to the SCIG facility, and one-million two-hundred thousand
more would go to the ICTF facility to its North. I accept that number.
·
IF the General Atomics ‘model’ rail-towed
street-wheeled container trailer were used, there would be TWO MILLION TWO
HUNDRED THOUSAND more INDIVIDUAL “mini train” trips to SCIG and ICTF each
year. That’s 6,027 MORE REMOTE driven
trips A DAY!
·
While the website touts individual trailer
components being feasible, it is simply unrealistic to envision that many
unmanned vehicle trips going “through the neighborhoods” every day. On the other hand, the maximum trailer
‘consists’ they report as being technically possible is twenty per
consist. 6,027 / 20 = 301.35. That is still a HUGE volume of unmanned
mini-trains to be passing through ‘our neighborhoods’. All graphics suggest that trains would NOT be
twenty TEUs, but rather blocks of four (1,204 daily trips).
This does not square with
trains having twenty TEU trailers, unless they envision not simply modifying
track, but replacing it with shorter segments.
Refer to pages 3 and 4 of the ‘Zero Emissions ECMS
presentation for POLB/POLA. It shows a
four rail-wheeled bogey with trailer hitch. It shows it towing individual
container trailers that have the usual rubber wheels in four clusters of two,
or four wheels per axle.
I have seen many container trailers that are bent or out of
line. It is only the drivers skill that
keeps then in their lane on the roadway.
Such trailers towed over rails are likely to run into or over railside
obstructions beyond the railroads ability to keep clear (abandoned cars,
refrigerators, junk, etc. Alternatively-trailer brakes can lock or catch
fire during remote dragging.
Trains have engineers and safety warning horns. Unmanned rail-towed highway trailers are not
so equipped, nor would it be feasible to man them unless the port is going to
mandate hiring three hundred to twelve hundred new mini-train operators each
day.
In fairness, the General Atomics design by inference clearly
envisions an above grade-crossing system.
It is not feasible or practical to build such a system to
reach Terminal Island wharfs all the way to and from the SCIG (and ICTF)
1.
The Heim lift bridge adjacent rail line could
not handle 300 to 1200 individual mini train trips a day.
2.
Even if a bridge could handle that many trips,
navigation would be impeded due to inability to lift the bridges (trains cannot
handle too steep a grade, so the rail level tends to be near the water
surface).
3.
Building new bridges would require even more
condemnation of leased property within the Port and into nearby Wilmington and
Long Beach.
4.
Increasing the number of new Maglev lines
increases danger from unmanned vehicles.
5.
The “proposed” Maglev lines would require
complete replacement of all existing rail lines with embedded maglev
lines. It is not feasible to shut the
Port down for the several years building the in-ground LSM power lines would
take, even if the new right of ways were available.
6.
Net environmental or cost benefits when the huge
amount of per trip energy generation requirements are considered, do not seem
probable. I am also considering the
generation costs in terms of money and pollution for the electricity. We are
not talking about 110v or 220 volt systems. We are talking about 395Kvh systems
PER TRAIN! Even with probable cycling,
the amount of energy required is huge.
7.
MagLev cost savings are promoted based on
efficiencies and scales that are not applicable to heavy container freight
hauling. The data cited in lines 24 to 40
also included REAL data on why the first MagLev line ever built was abandoned
only fifteen years after it was built due to higher than expected wear and
maintenance costs.
8.
Of the 20 +/- Maglev or HSR lines built, 10%
have had catastrophic accidents. Catastrophic in this sense is where death
occurred, though others had accidents with property and serious infrastructure
damage took place.
9.
The ONLY safe method of commuter Maglev is with
above grade crossings and lines. It is
unknown if this would be adequate for heavy freight since the speeds and
physics are so different than light rail passenger lines.
10. The
Los Angeles Metro Line routinely kills several people each year. Let’s not increase that annual death toll
using far heavier freight carrying hybrid technology that is untried, and still
in the very early commercial use experimental stages.
11. Eventually
the technology will be state of the art – but it has not reached that yet.
12. It
took forty years (1912) to 1960 for LSM technology to evolve to patentable
meaningful uses. The first passenger
Maglev was not built until 1989, and is no longer in operation. The system could be well suited to replace
short distance (500 or 600 mile) air travel, and maybe even cross country
travel, but it is not yet suitable for heavy freight movement. We cannot delay the SCIG for another twenty
years waiting on Maglev / LSM/LIM.
My other issue or concern is the
apparent desire on the part of certain “environmental advocates” to kill, or
delay this project as long as possible, based on health based scare tactics,
and outright racism. I chose to live
where I live. It IS an ethnically and
culturally diverse community that I dearly love. That does not mean that either I or my
neighbors are too ignorant to speak for ourselves, or that we need some
ambulance chasing “environmental justice” attorney claiming the project should
be stopped for no other reason than we are collectively “people of color”. Whether we oppose or support SCIG, I don’t
believe there is one among us that seriously believes this project location
selection was, or is, race based. It is
an industrial use project located in an appropriately zoned industrial use
area. It conforms to zoning, specific
plan and Tidelands Grant Act mandates.
When the POLA and BNSF originally
conceived this project, it was ten years ago. It has taken this long to reach
the present Draft EIR stage of the process, and IF everything goes well, it
would be another 3 years before SCIG could operate.
BNSF followed the rules and guidelines
in place when they applied for this project.
All plans have a certain amount of flexibility, and it is clear that
BNSF modified their plans to incorporate state of the art, PROVEN technology
with strong attention to environmental and health concerns. They have also agreed to sequential upgrades
of equipment according to a documented schedule, and in accordance with, or
better than reasonably foreseeable standards and technologies. As one resident suggested at the Silverado Park public hearing, they
have already offered to build a sound attenuation / mitigation wall between the
project and the West Side residents. The
sticking point is the City of Long Beach itself, refusing (so far) to make the
land for such a wall available.
I have to wonder why MY city is
refusing to cooperate with a reasonable request from residents in the affected
area for a sound wall. With or without
the project, such a wall along the TI Freeway makes sense. Long Beach now has the chance to have the
wall built at someone else’s (BNSF) expense.
There was also a cynical and
emotional exhortation by a self-identified Cabrillo High School teacher to the
effect that the DEIR could not be trusted because it is prepared by or at the
behest of BNSF. I'd like to know if this
teacher is (1) a resident within the impacted project area, (2) speaking on behalf of Cabrillo High School &
LBUSD, and / or (3) If he is simply an environmental ‘conscientious objector” that
opposes industrial progress in general.
I respectfully remind the POLA and
POLB that Cabrillo High and Admiral Kidd Park were built long after the
industrial uses that are on the SCIG site now.
Use that is similar in nature and character to that being proposed.
Lastly, Cal-Cartage and the Grain
Shipping firm currently on the site are afraid of losing their businesses and
the many hundreds of jobs they support.
My reading of the DEIR indicates relocation is intended for Cal-Cartage
at the South end of the site. Other
sources tell me that location is far smaller , and inadequate compared with
what they have now.
I don’t know what leases are in
effect, but surely there is a moral obligation to assist them both in finding
new sites for their businesses within or very near to the harbor. POLA routinely helps tenants to relocate
within the Harbor area. Please make a
sincere effort to do the same for those two firms. Growth and progress should not be so
mercenary that you forget or ignore the needs of your loyal, long term tenants
too.
Please adopt the DEIR without
further delay.
Respectfully submitted,
Michael F. Ford,
Resident, West Long Beach
Info: “Maglev was invented in
1912 by a New Yorker. In 1964 Powell and Danby of Brookhaven National Labs on Long
Island, NY invented a practical form of repulsion maglev utilizing
superconducting magnets, the technique later adopted by the Japanese. The U.S.
government sponsored maglev research in the early 70s ,…...”
The
formula at : http://faculty.washington.edu/jbs/itrans/suppes.htm
(line 200 above) has an error in the stated formula under Magnetic Drag. The stated formula says that “S” =
conductivity of the track, the example indicates that it is “K” that is
conductivity of the track. It appears to
be a typographical error only however anyone relying on this formula to
calculate magnetic drag with various loads, speeds or differences in systems
should verify the form
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