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Additional commens may be found at: el F.http://www.mfford.blogspot.com/ Ford November 11, 2011
1956 Fashion Avenue
Long Beach, CA 90810
(714) 366 9404 Mike@MFFord.Com
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)
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;and the same firms “Zero Emissions” Propulsion on Standard Railway / Roadway Infrastructure presentation for GreenTech Forum August 3-4, 2009 (Pasadena Convention Center seminar).
I also studied the History of Existing Maglev Systems Encyclopedia II; General Atomics other website publications, POLA press releases re maglevs 11/28/2006 and 03/22/2007 (Updated economic impact study re POLA/POLB & Alameda Corridor); the General Atomics Low Speed Urban MagLev Technology Development Program TRB 2003 annual report; ITSC Port Container Moving System; General Atomics MagneRail website pages, General Atomics website news releases re Maglev from 05/1998 through 12/2007; Article 2011 North American Maglev Transport Institute http://namti.org/?page_id=9 Maglev vs. Train Comparisons which includes (online) video links of spectacular collisions involving high speed maglev movers. Lastly,” A Perspective on Maglev Transit and Introduction of the PRT Maglev” by Galen Suppes, Dept. of Chemical & Petroleum Engineering, University of Kansas
Based on the above, the following CRITICAL observations are made:
I submit that ONE such unmanned trip over the current rail system is too much for safety. The developer states that only one car can be present on a rail section at any one time, therefore “collisions are impossible”. This does not square with trains having twenty TEU trailers, unless they envision not simply modifying track, but replacing it with shorter segments.
- 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 RELEVENCE 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 onboard 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).
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)
- The Heim lift bridge adjacent rail line could not handle 300 to 1200 individual mini train trips a day.
- 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).
- Building new bridges would require even more condemnation of leased property within the Port and into nearby Wilmington and Long Beach.
- Increasing the number of new Maglev lines increases danger from unmanned vehicles.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Eventually the technology will be state of the art – but it has not reached that yet.
- 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 need to know if this teacher is (1) a resident, (2) speaking on behalf of Cabrillo High School & LBUSD, and (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