Coastal effects of coal transshipment in Michigan an evaluation strategy

[From the U.S. Government Printing Office, www.gpo.gov]

0
(O&L URMWHOMMU N MCHRAMO

Prepared for

The State of Michigan Department of Natural Resources
Division of Land Resource Programs- Coastal Energy Impact Program
by the Staff of the Great Lakes Basin Commission

COASTAL EFFECTS OF COAL TRANSSHIPMENT IN MICHIGAN:

AN EVALUATION STRATEGY

Prepared for

The State of Michigan
Department of Natural Resources
Division of Land Resource Programs
Coastal Energy Impact Program

"IN Karl R. Hosford, Chief
Division of Land Resource Programs

Chris A. Duncan, Contract Manager
under contract CEIP 80-8

by the Staff of

Great Lakes Basin Commission
Charles A. Job, Project Manager

October 1980

This publication was prepared through financial assistance provided by the Michigan
Department of Natural Resources, Division of Land Resource Programs and the Office
of.Coastal Zone Management, National Oceanic and Atmospheric Administration, United
States Department of Commerce.

'US Dnnartment of CommerCe
IqC'- -istal Scrvices Center Library
22. -ath Hobson Avenue
[Cha-ieston, SC 29405-2413

Published in 1980 by the Great Lakes Basiln Commission, 3475 Plymouth Road,
Post Office Box 888, Ann Arbor, Michigan 48106. Lee Botts, Chairman@
Charles A. Job, Project Manager; Robert Kloepfer, Jeff Christensen, Thomas
Crane, Sharon Meier., Robert CZemens-, Paul Horek, PZanners/AnaZysts; Jeff
MyZZ
_, Timothy Monte*th, William Sonzogni_, Technical Assistance; Joan
Morrell, Karen Edwards., Judy HaZZ., Production; Chris Duncan_, Michigan
Department of Natural Resources (DNR) Contract Manager; Ron Webster, DNR
Cover Design; Detroit Edison Company, Photographs.

ABSTRACT

Coal use will increase steadily in Michigan between 1980 and 2000.
The deliberate, undramatic nature of this growth reflects the substantial coal
use in Michigan already. Thirteen coastal coal unloading facilities are
expecting major increases in deliveries, and five will be physically, expanded
to handle larger coal shipments during the 1980's.

While Michigan is the single largest user of coal shipped on the
Great Lakes, most coal is delivered to Michigan by rail. For c oal used in
coastal areas, lake vessel delivery can minimize the land area required. For
large facilities, lake vessel delivery is dictated not only by the source of
the coal but also by the facility's ability to handle rail delivery.

Generally, coal is a safe commodity to transport and deliver. Coal
is a relatively inert substance. However, potential negative effects of coal
unloading and transshipment include: fugitive coal dust generation, release
of toxic substances from sediments, aquatic ecosystem disruption, erosion,
noise, and land use conflicts. Although not all these effects will be
significant at every facility expansion or development, their possibility must
be considered, especially since mitigation measures are available to reduce or
avoid them.

Key recommendations for Michigan state policy include: (1) developing
a policy on future coal use, (2) developing programs to minimize onshore
vessel impacts, (3) examining low-cost solutions to rail interference with
community activities, (4) preparing a coordinated, flexible long-range
dredging and dredge disposal plan, (5) considering alternatives to channel
improvements, (6) evaluating public access in proposals for coal-related
development, (7) conducting studies concerning the effects of coal and
coal-dust on the aquatic environment, (8) integrating planning and permit
processes for coal transshipment facilities with those of other energy
facilities and an overall energy facility siting process, (9) using coastal
energy impact program funds to mitigate the effects of coal facility
expansion, and (10) using permit renewals to enhance existing coal facilities.

iii

COASTAL EFFECTS OF COAL TRANSSHIPMENT IN MICHIGAN:
AN EVALUATIONITRATEGY

Table of Contents

Page No.

Title Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
Abstract . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . iii
Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . iv
List of Tables and Figures . . . . . . . . . . . . . . . . . . . . . . vi.
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii.i
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

Section I--Introduction

1. Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2. Purpose of the Study and the Report . . . . . . . . . . . . . 2
3. Findings and Conclusions . . . . . . . . . . . . . . . . . . . 3
4. Outline and Use of the Report . . . . . . . . . . . . . . . . 8

Section II--Projections of Coal Use and Facilities Development

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 10
2. U.S. Coal Projections . . . . . . . . . . . . . . . . . . . . 12
3. The Great Lakes States Relative to the Nation . . . . . . . . 22
4. Michigan Coal Projections . . . . . . . . . . . . . . . . . . 29
5. Projected Location and Type of Coal Transshipment
Faci.lity Expansion and Development . . . . . . . . . . . . . . 51

Section III--Evaluation Strategy and Guidelines

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 55
2. Evaluation Strategy . . . . . . . . . . . . . . . . . . . . . 55
Part 1 - Transportation
A. Water Transportation . . . . . . . . . . . ; . . . . 64
B. Rail and Truck Transportation . . . . . . . . . . . 73
(1) Noise . . . . . . . . . . . . . . . . . . . . . 73
(2) Fugitive Dust . . . . . . * , -I . . . . . . . . 80
(3) Cormnunity Effects from Rail Transport . . . . . 81
(4) Road Damages from Truck Transport . . . . . . . 86
Part 2 - Facility Development and Operations
A. Dredging Activities . . . . . . . . . . . . . . . . 89
B. Dredge Material Disposal . . . . . . . . . . . . . . 93
C. Nearshore Construction . . . . . . . . . . . . . . . 99
D. Facility Development for Land Delivery . . . . . . . 105
E. Operations for On-Site Handling of Coal . . . . . . ill

Page No.

Supporting,Appendices

Policy Recommendations for Michigan Coal Facilities . . . . . . . A-1

Projections
Historical Coal Movement in Michigan Ports, Waterways
and Rail Lines . . . B-I
Results of,the Coal Facility Review . . . . . . . . . . . . . . . C-I
1. Michigan . . . . . . . . . . . . . . . . . . . . . . . . . C-9
2. Great Lakes States . . . . . . . . . . . . . . . . . . . . C-16
Michigan Power Plants . . . . . . . . . . . . . . . . . . . . . . D-1
Factors and Policies Affecting Future Coal Use . . . . . . . . . . E-I

The Coal Production-Consumption Cycle . . . . . . . . . . . . . . F-I

Environmental Effects
Environme;tal Effects -An Overview of the Chemical
and Physical Characterization of Coal . . . . . . . . . . . . . G-1
Comprehensive Mitigation Strategy . . . . . . . . . . . . . . . . H-1

Policy Review
Review of Michigan and Federal Policies . . . . . . . . . . . . .
1. Energy Policy and Coal . . . . . . . . . . . . . . . . . . 1-8
2. Transportation Laws and Programs . . . . . . . . . . . . . 1-15
3. Environmental Laws and Programs . . . . . . . . . . . . . 1-36
4. Recreation Planning . . . . . . . . . . . . . . . . . . . 1-86
5. Relationship of Federal and State Coastal Zone
Management Programs to Coal Transportation . . . . . . . 1-89
6. Port Development in Michigan . . . . . . . . . . . . . . . 1-96
7. Organization of Michigan DNR . . . . . . . . . . . . . . . 1-99

Matrix of Michigan Energy Policy . . . . . . . . . . . . . . . . . J-1

REFERENCES

LIST OF TABLES AND FIGURES

Table No-

I Coal Consumption by End-Use Sector, 1949-1979 . . . . . . . 13
2 Energy Sypply and Disposition Balance, 1960-1979 . . . . . . 15
3 United States Coal Transport - 1978 . . . . . . . . . . . . 17
4 Total Resource Use by Fuel 1975 to 2000 NEP-Il
High World Oil Price . . . . . . . . . . . . . . . . . . . 19
5 Macroeconomic Assumptions of the NEP-II High Scenario . . . . 20
6 Projected National Coal Transport Modes, 1985 . . . . . . . . 21
7 Great Lakes Consumption . . . . . . . . . . . . . . . . . . 23
8 Summary of Coal Movement Through the Great Lakes Ports
v. Total Movement Through U.S. Ports - 1977 . . . . . . . . 24
9 Projections of U.S. Great Lakes Shipments of Coal . . . . . . 28
10 Patterns of Energy Consumption in Michigan 1977 . . . . . . . 31
11 Shipments of Bituminous, Subbituminous, and Lignite
Coal to Mi.chigan 1975-1979 . . . . . . . . . . . . . . . . 32
12 Saulte Ste. Marie: Unconstrained Traffic Lock Capacity,
Tonnage Lost, Total Traffic by Commodity Group . . . . . . 43
13 Locations of Increased Coal Delivery and Projected Coal
Unloading Facility Expansion and Development in
Michi-gan Coastal Counties . . . . . . . . . . . . . . . . . 52

Appendices

B-1 Port Trends 1970-1977 B-2
B-2 Waterway Trends 1970-1977 . . . . . . . . . . . . . . . . . . B-4
B-3 Recent Past History of Coal Receipts and Shipments in
Michigan Harbors and Ports . . . . . . . . . . . . . . . . B-6
B-4 Recent Past History of Coal Movements on Michigan
Waterways . . . . . . . . . . . . . . . . . . . . . . . . . B-8
B-5 Port Coal Receipts by Coastal County - 1975 . . . . . . . . . B-10
B-6 Railroad Coal Shipments by Coastal County - 1975 . . . . . . B-11
B-7 Unit Coal Train Routes within Michigan . . . . . . . . . . . B-12
C-1 Origin Data . . . . . . . . . . . . . . . . . . . . . . . . . C-4
C-2 Mode Data . . . . . . . . . . . . . . . . . . . . . . . . . . c-4
C-3 Point of Vessel Loading Bound for Michigan . . . . . . . . . c-5
C-4 Use Data . . . . . . . * * ' : * * * * * * * * . . ... . . . C-5
C-5 Number of Individual Coal Receipts . . . . . . . . . . . . . c-6
C-6 1979 Throughput . . . . . . . . . . . . . . . . . . . . . . . C-7
C-7 Throughput Capacity Data . . . . . . . . . . . . . . . . . . C-7
C-8 Regions of Greatest Coal Use . . . . . . . . . . . . . . . . C-8
C-9 Projected Tonnage Changes . . . . . . . . . . . . . . . . . . C-8
C-10 Michigan Facility Review . . . . . . . . . . . . . . . . . . C-9
C-11 Other Lakes State Facility Review . . . . . . . . . . . . . C-17
D-1 Michigan Power Plants (OPR & STN) . . . . . . . . . . . . . . D-2
D-2 Michigan Power Plants (CON, PLN & I/P) . . . . . . . . . . . D-6
E-1 Coal-Capable Utility Plants in Michigan Burning Oils or
Gas as of January 1980 According to the U.S. Department
of Energy . . . . . . . . . . . . . . . . . . . . . . . . . E-2
E-2 Department of Energy Projected Emerging Energy
Technologies in the Great Lakes Basin . . . . . . . . . . . E-5

E-3 Coal-Capable Utility Plants Burning oil of Gas in the
Great Lakes States as of January 1980 According to the
U.S. Department of Energy . . . . . . . . . . . . . . . . . E-10
E-4 Projections for Electric Cars . . . . . E-14
E-5 Summary of Major Constraints Affecting U.S. Coal
Production Expansion . . . . . . . . . . . . . . . . . . . E-16
E-6 Coal Production Development States . . . . . . . . . . . . . E-18
E-7 Factors Affecting Industrial Boller Conversion to Coal . . . E-20
F-1 Projected U.S. Coal Production by Region . . . . . . . . . . F-5
F-2 Sources of Bituminous Coal and Lignite for Michigan . . . . . F-6
F-3 Projected National Coal Transport Modes, 1985 . . . . . . . . F-8
F-4 Coal Slurry Pipelines . . . . . . . . . . . . . . . . . . . i F-11
G-1 Coal Unloading . . . . . . . . . . . . . . . . . . . . . . . G-9
G-2 Coal Transshipment . . . . . . . . . . . . . . . . . . . . . G-9
G-3 Facility Operation . . . . . . . . . . . . . . . . . . . . . G-10
G-4 Stockpiling . . . . . . . . . . . . . . . . . . . . . . . . . G-10
G-5 Facility Construction . . . . . . . . . . . . . . . . . . . . G-11
I-1 Major Legislation Applicable to Coal Supply and Demand,
Transportation, Handling and Facility Development . . . . . 1-2
1-2 Maximum Overall Dimensions . . . . . . . . . . . . . . . . . 1-32
1-3 Table of Maximum Allowable Gross Axle Loadings . . . . . . . 1-33
1-4 Impacts on Fuels in 1995 . . . . . . . . . . . . . . . . . . 1-39
1-5 National Ambient Air Quality Standards for Particulate
Matter, Sulfur Dioxide, and Nitrogen Dioxide . . . . . . . 1-40
1-6 Summary of Potential Water Pollution from Coal Transport
Activities and Identifi.carion of Current Regulatory
Framework . . . . . . . . . . . . . . . . . . . . . . . . . 1-61
1-7 Summary of State Protection of Historic and Cultural
Resources under CZMA . . . . . . . . . . . . . . . . . . . 1-93
1-8 Summary of State Laws Affecting Management of Coastal
Development . . . * ' * * * * * * * * * * * * ' ''* * ' ' ' 1-94
Matrix of Michigan i
J-1 Energy Policy . . . . . . . . . . . . . . J-1

Figure,# Page No.

1 Demonstrated Coal Reserve Base by State, January 1, 1980 14
2 Electric Utility Electricity Flow Diagram, 1979 . . . . . . . 16
3 Coal Use Overview . . . . . . . 23
4 Michigan Rail Network - Major Coal Routes 1978 . . . . . . 35
5 Coastal Counties Receiving Coal by Rail in 1975 . . . . . . . 36
6 Coastal Counties Receiving Coal by Water in 1975 . . . . . . 37
7 Map of Michigan's Regions . . . . . . . . . . . . . . . . . 54

Appendices

F-1 The Coal Production Consumption Cycle . . . . . . . . . . . . F-2
F-2 Coal Slurry Pipeline Systems . . . . . . . . . . . . . . . . F-13
I-1 Maximum Gross Axle Loads . . . . . . . . . . . . . . . . . . 1-34
1-2 Maximum Gross Vehicle Weights in Michigan in 1970 . . . . . . 1-35
1-3 Michigan Natural River System . . . . . . . . . . . . . . . . 1-83

vii

PREFACE
L-

With large projected increases in coal use, the Department of Natural
Resources, Division of Land Resource Programs, Coastal Energy Impact Program
was concerned about the ability of Michigan's coastal zone to handle the
demands of greatly increased coal shipment. The extent of future coal
deliveries, the need for additional coal unloading and handling facilities,
the incremental effects of expanding coal use, and the available mitigation
measures that should be considered in reviewing proposed facilities were major
topics requiring investigation. The intent of this report is to give the
Department a planning document for policy development and a handbook for
project rev-iewers.

viii

ACKNOWLEDGEMENTS

The Michigan Department of Natural Resources and the
Great Lakes Basin Commission, study contractor, appreciated
the opportunity to do thi-s report which was funded by the
Office of Coastal Zone Management, NOAA, U.S. Department of
Commerce, and appreciate the cooperation of the companies
listed in Appendix C, and many individuals from local, state
and federal government who assisted in providing information
and perspective on future coal use, unloading and
transshipment in Michigan. In particular, the assistance of
the Detroit Edison Company, the Consumers Power Company, the
Lake Carriers Association, Mr. Max McCray, Port of Monroe
Michigan Department of Transportation, the U.S. Army Corps of
Engineers, the U.S. Maritime Administration, the Great Lakes
Environmental Research Laboratory, the St. Lawrence Seaway
Development Corporation, the New York and Chicago offices of
the Federal Energy Regulatory Commission is appreclated. The
cooperation of these companies, organizations, and agencies
does not imply their endorsement of the report or its
conclusions and recommendat: ions. The Commission staff is
grateful for the tours provided by the Detroit Edison Company
of its River Rouge and Monroe coal transshipment facilities.
The photographs were contributed by the Detroit Edison
Company.

SECTION I

INTRODUCTION

COASTAL EFFECTS OF COAL TRANSSHIPMENT IN MICHIGAN
AN EVALUATION STRATEGY

SECTION I

INTRODUCTION

OVERVIEW

Coal use in Michigan is expected to increase. This increase will be
gradual rather than dramatic, partly because the state already uses much coal
in both the utility and industrial sectors. The extent of the growth will be
influenced by the implementation of coal conversion orders, continued energy
conservation, production and use of the electric car, production of synthetic
coal gas, and environmental controls on stack emissions. Increased use will
in turn magnify demands on transportation, particularly by waterways, ports
and railroads in coastal areas.

In most cases, Michigan's coal transportation system can accomodate
future demands. In other cases, expanded or new facilities will be needed,
and these developments should- be evaluated for their effects on communities
and the environment. Overall, coal is a safe commodity to transport and
handle. However, site-specific circumstances may dictate a more extensive
analysis of particular anticipated effects. This report provides a systematic
approach to evaluating and mitigating these potential effects.

PURPOSE OF THE STUDY AND THE REPORT

This study (1) indicates the new and expanded facilities needed to
accomodate future coal use, (2) provides systematic guidelines to evaluate the
potential effects of these new or expanded facilities on communities and the
environment, and (3) indicates additional state policy needed to accomodate
new or expanded coal transport and unloading facilities.

The focus of this study, responding to the specific needs of the
Michigan Department of Natural Resources, is on environmental and community
effects of constructing and operating coal unloading and transshipment
facilities. The study was not intended to recommend which facilities should
be developed or to suggest improvements in the engineering of facilities.
Thus, the report describes the full range of effects of coal unloading and
transshipment facilities and the principal mitigation measures available.
Since not all the effects described will occur at every facility, the
magnitude of the effects will vary from facility to facility. This report's
evaluation guidelines simply provide a checklist for both a facility's
proposer and the state's reviewer.

FINDINGS AND CONCLUSIONS

Future Coal Use

Michigan's coal use will increase steadily rather than with a large
near-term demand. Michigan utilities and industries already use coal for a
major portion of their energy. Therefore, massive conversions will not take
place and no dramatic shift in demand will occur in the near-term. Michigan's
coal use will probably increase by 50 to 75 percent over the next twenty years.

The electric utility sector is the largest consumer of coal in
Michigan now. This dominance is expected to continue in the future, with
major increases in coal use also occurring in electric utilities. Conversion

to coal in other industries will be limited.

Projections indicate that the principal factors affecting future coal
use will be its delivered price relative to other sources of energy, the cost
of installing, operating and maintaining coal combustion and pollution control
equipment relative to other energy sources, and the reliability of the coal
supply.

Projected Coal Unloading

Most national forecasters are optimistically using figures based on
the National Energy Plan (NEP) that are derived by doubling coal use from
1978-9 to the year 2000. If current coal users dominate future use and they
double coal use by the year 2000, current unloading facilities in Michigan's
coastal areas could.handle this doubling and more. Thirteen locations along
Michigan's coast are expected to increase coal deliveries during the 1980's.
Five will be expanded.

Future Expansion in Coal Unloading Capacity at Existing Large Facilities

A review of expected coal facility construction along Michigan's
coast shows that expansion of coal unloading capacity will generally occur at

the locations of the larger coal users, predominantly in the southern lower
peninsula where waterfront land has high value.

Coal Unloading is Part of Larger Coal-Using Facility

The effect of coal unloading in Michigan is difficult to separate
from the effect of the larger coal-using facility, and this limits the
analysis of relative coal use effects and socio-economic effects. Future
analyses should consider the planning and the effects of the larger coal-using
facility -- for boiler fuel or for feedstock for synthetic fuels and products.
Each facility has different coal unloading requirements for water or rail
access, storage area available, and rate of coal use. Coal unloading is an
integral part of the entire coal-Psing facility and is af fected by
alternatives for the larger facility.

Not All Impacts at Every Proposed Facility

Not all the impacts described in this report will occur or be
important for every coal unloading and transshipment facility. The effects of
facility expansion will generally be several orders of magnitude less than the
effects of a new facility. In any case, the extensive list of environmental
effects should not be presumed to be an indictment of future coal use. Th i s
is a checklist to insure that facilities are developed compatibly with the

environment.

Major Effects

Generally, experts agree that coal in water does not have any major
deleterious effects. Some experts maintain that coal particulates in water
can improve quality in already polluted water by adsorbing organic chemicals
to them and then settling out in sediments. However, coal dust will have no
beneficial effects in unpolluted waters. Because of its inert nature, a
substantial volume of coal deposited on submerged lands would smother aquatic
habitat and not provide a base for reestablishing the habitat. Major
accumulations of coal or coal particulates in the Great Lakes have not been

documented.

The principal potential effects of coal unloading are water turbidity
and community disruption. Overall, these are minor. However, at specific
locations, these effects may be very significant and adverse. Turbidity would
be caused by a high concentration of coal particulates in water from runoff,
spillage or atmospheric fallout from coal storage, delivery, or on-site
management. Community disruption could be caused by transporting coal
through populated coastal areas, especially by long unit trains tying up
traffic and generating continuing noise at regular intervals.

The main problem prescribed by coal transshipment facilities along
the coast is using land which is then not available for other purposes,
especially for recreational purposes. Access to shorelands for recreation is
an increasing concern of the public, and raises the policy question of placing
priorities on competing uses of shorelands.

The other effects described in this report are generally considered
minor, but on a site-specific level could be significant.

Effects in Perspective

Coal transportation and delivery is considered by most experts to be
far less a problem than burning coal and generating sulfur dioxide which can

result in acid rain.

Similarly, comparing the environmental impacts of coal transporting
and unloading with the effects of the same activities for other bulk
commodities, shows that coal is not an especially noxious substance. With the
exception of coal dust generation, unit train disruption of communities, and
competition with other shoreland uses, many environmental effects identified
in this report could be connected with the transport and handling of many bulk
commodities under similar conditions. Specifically vessel effects, noise,
dredging effects, and many impacts related to nearshore construction are
by-products during delivery, processing, and facility development for many
commodities, and are certainly not exclusively related to coal unloading and
transshipment. The results of this study remain significant, however, in that
coal unloading is one activity which does have these effects, and the

mitigation strageties and review guidelines in this study will help prevent
and mitigate the impacts of coal transportation, handling, and facility

development .

Coal, Unloading Guidelines Should be Part of Energy Facility siting

Evaluation guidelines for coal unloading facilities should be part of
overall energy facility siting. If coal is unloaded, it is unloaded with the
intent of using it in an adjacent activity. If an evaluation determines that
a proposed coal unloading facility is poorly located, most likely the
associated coal-using plant is also poorly located. Alternatives to using
coal and to the location of the plant should be evaluated under state and
federal environmental impact review regulations. Energy facility siting
should be comprehensive and should also be part of a state energy plan or
policy. A flexible state energy plan might be the most workable. Energy
facility siting should include all types of energy facilities -- coal, oil,
nuclear, wood and refuse electrical generation and process heat and steam,
solar, wind, wave, biomass, above and below ground transmission lines,
cogeneration and combined-cycle.

Energy facility siting should comp lement private sector planning and
not complicate planning by companies not currently regulated. In any case,
because of the major investments involved, the process should not impose
unnecessary added costs or result in a commitment to technologies which are
rapidly changing and may become obsolete. Protecting the public trust as well
as the market place should be clear in the formulation and implementation of a
siting process.

Application of the Coastal Energy Impact Program

To provide a comprehensive approach to mitigating the potential
effects of increasing coal use and provide further benefits of existing coal
use, the state and national coastal zone management programs should consider
using coastal energy impact program (CEIP) funds to ameliorate the effects of
coal facility expansion, and using permit renewals to enhance existing coal
facilities. Specifically, the CEIP funds could be used to assist communities

during construction of a project or provide public access and facilities in
areas of heavy demand. At existing coal unloading and using sites, the state
could work with the coal transporting or using company in the permit renewal
process to provide additional shoreline access. CEIP funds might then be used
to provide boat launches, fishing piers and other recreational features when
they do not exist locally. In such a program, small boat areas should be
separated from docking areas used by large vessels to protect small boat
operators from harm potentially posed by the manuevering of these different

kinds of vessels in the same area.

OUTLINE AND USE OF THE REPORT

The remainder of this report is divided into three major sections:

Projections of Coal Use and Facility Development
Evaluation Strategy and Guidelines
9 Supporting Appendices

Projections of Coal Use and Facility Development

This section reviews national and state projections of coal use.
Factors affecting future coal use are also reviewed in an appendix.
Facilities expecting expansion are shown.

Evaluation Strategy and Guidelines

The Evaluation Strategy and Guidelines are organized for the state
project reviewer's use. This systematic review covers:

1. the major activities related to coal unloading and transshipment

2. the effects of the activities

3. laws and policies relating to the activity and its effects
4. mitigation measures
5. guidelines in the form of questions to serve as the basis for a review
of any proposed coal unloading and transshipment facility
6. needed policy changes for enhancing state environmental authority for
dealing with future coal unloading and transshipment facilities

Supporting Appendices

The appendices provide additional information for the project
reviewer, including:

� a review of factors affecting future coal use
� a review of historic and projected coal use in Michigan and the United

States

0 an outline of the coal production-consumption cycle
0 a review of Michigan and Great Lakes ports, with emphasis on future
coal handling
0 a detailed characterization of the effects of coal unloading and
transshipment operations and facilities
0 a review of laws, regulations, and policies

This organization gives the project reviewer the most important
information first, with more detailed information appended at the back.

SECTION 11

PROJECTIONS OF COAL USE AND FACILITIES DEVELOPMENT

SECTION II

PROJECTIONS OF COAL USE AND FACILITIES DEVELOPMENT

INTRODUCTION

Facilities at some locations in Michigan will need expansion to
accomodate future increases in coal deliveries. At the same time, other
locations project decreasing use of coal and, therefore, decreasing coal
shipments. One reason for this second circumstance is that older electrical
generating plants of small municipal utility companies will be slowly phased
out or used less while these municipal utilities buy power from the state's
larger companies. This situation reinforces the projected increases in coal
delivery and use by large coal users.

Coal unloading facilities in Michigan's coastal areas, when taken as
a whole, are capable of handling a doubling of coal deliveries. However,
because of the varying demand for coal at different locations along the coast,
additional unloading facilities will be needed at some sites.

Michigan's waterways and rail lines, the principal transport paths,
also have generally adequate capacity to handle the projected increase.
Particular locations may need attention in the future, however.

Projections of coal use and transportation must be put into
perspective. Coal use nationally accounts for 19% of all energy used. In
Michigan, it currently serves 30% of the state's energy needs. Federal policy
aims to increase coal use nationally by 150% (more than a doubling) by the
year 2000. However, since coal is already a major fuel in Michigan and
.Michigan industries have established plant capabilities, Michigan probably
will not double its coal use over the next 20 years. A reasonable and
practical estimate of future coal use in Michigan is an increase of 50 to 75
percent by the year 2000.

Outline of this Section. The rest of this section will (1) review
historic and projected national coal use and transportation, (2) review
historic and projected Michigan coal use and transportation, and (3) describe
projected coal transshipment facility developments in Michigan. This will
provide the Department of Natural Resources with basic information for
anticipating proposals for coal transshipment facilities and potential effects.

Appendix E, "Factors Affecting Future Coal Use," gives an overview of
major factors encouraging and constraining future coal use at the state,
regional and national levels.

U.S. COA4 PROJECTIONS

HISTORIC SUPPLY AND USE

Of the last thirty years, 1979 was the year of the largest absolute
increase in coal consumption not preceded by a year of major decline in
production, whether measured on a tonnage basis--an increase of 55.7 million
short tons, or on a Btu basis--an increase of 1.23 quadrillion Btu. Total
consumption of coal in 1979 was 680.9 million short tons, or 15.08 quadrillion
Btu. Electric utilities accounted for nearly 78 percent of the coal consumed
in 1979, while other industries used 21 percent. Table 1 shows the changes in
coal consumption by the End-Use Sector from 1949 to 1979. The largest
absolute increase in coal supply in the United States over the last thirty
years also occurred in 1979, an increase of 105.6 million short tons for a
total supply of 775.8 million short tons.

The U.S. Demonstrated Coal Reserve Base by state is shown in Figure
1. The Appalachian and Central coal regions, the areas closest to Michigan,
have about two-thirds of the nation's demonstrated coal reserves.

In 1979, coal represented 28 percent of the nat ion's energy
production. Of the coal produced, 10.2 percent was exported. Coal was 19
percent of total energy consumption in 1979. Table 2 gives details of energy
supply and consumption since 1960. Coal use by electric utilities acounted
for 47.8 percent of the electricity produced (2,248 billion kilowatt-hours) in
1979. An overview of fuel for electrical generation in the United States is
given in Figure 2.

COAL TRANSPORTATION IN THE UNITED STATES

At the national level, most coal is transported by rail. This trend
is expected to continue into the forseeable future. In 1978, 54 percent of
coal moved by rail, 19.4 percent by water, 15.6 percent by truck, and 11.0
percent by other means. See Table 3.

TABLE 1

COAL CONSUMPTION BY END-USE SECTOR, 1 1949-1979
(Million Short Tons)4
Industry and Miscellaneous
Other Residential
Electric Coke Industry and and
Year Utilities Plants Miscellaneous Total Transportation Commercial Total

1949 84.0 (17.4) 91.4 121.2 212.6 (44.0) 70.2 (14.5) 116.5 (24.1) 483.2 (100.0)
1954 118.4 (39.4) 85.6 98.2 183.9 (47.2) 18.6 ( 4.8) 69.1 (17.8) 389.9 (100.0)
1959 168.4 (43.7) 79.6 92.7 172.3 (44.7) 3.6 (0.9) 40.8 (10.6) 385.1 (100.0)
H 1964 225.4 (50.6) 89.2 103.1 192.4 (43.2) 0.7 (0.2) 27.2 ( 6.1) 445.7 (100.0)
1969 310.6 (60.1) 93.4 93.1 186.6 (36.1) 0.3 (0.1) 18.9 ( 3.7) 516.4 (100.0)
1974 391.8 (70.2) 90.2 64.9 155.1 (27.8) 0.1 (0.0) 11.4 ( 2.0) 558.4 (100.0)
19793 528.9 (77.7) 77.1 65.9 143.0 (21.0) (2) (0.0) 9.1 ( 1.3) 680.9 (100.0)

1 See explanatory Notes I and 7
2 Less than 0.05 million short tons.
3 Preliminary
4 Numbers in parenthesis are percents. These percents may not total to 100% due to rounding.
NOTE: Sum of compenents may not equal total due to independent rounding.
NOTE: After 1977, small amounts of bituminous coal and lignite consumed by the Transportation Sector are included
in the Other Industry and Miscellaneous category.

SOURCE: U.S. Energy Information Administration, Annual Report to Congress, Volume 2, 1979, page 113.

FIGURE 1

DEMONSTRATED COAL RESERVE BASE BY STATE, JANUARY 1, 1980
(Billion Short Tons)

Appalachian Region
Total 111.7

Other
19%)
9.6 E.
Western Region W. Virginia KenVicky
(35%) (12%)
Total 222.0 38.6 13.5
Ohio
117%)
19.2
Wyorning Pennsylvania
(25%) (28%)
55.4 30.8

H
X-1
Montana
(54%) Colorado Central Region
120.6 (7%) Total 104.7
40 16.3
4 0 Other
(13%)
Other .7 13.5 W.
(9%) entucky
19.7 (12%)
Illinois 12.5
165%) Indiana
68.0 110%)
103

U.S. Total 438.3 Billion Short Tons
Note: Quantities -caled in proportion to area.

Doe deoionstiaw(l ieseivc. 1)ase of IJ.S. coal was estinialed to total 438 bilhoo 72 lwocent of the Nation's available coal. Montana aloof Wyooninq contained 40
(@r@e W
(@ntucky
1
12
20

slimt tons im of janomy 1, 1916. 1-to! laiq,si coal jini.,ws wele ill Mooldo.1, 1wrcent, p6ocipallV of lowee tjok subhotuminous coal. Coil in file thwe vast,m
111111o.., wyooloul, ww'I Vir(pola, aod I'voosylvaoia. These live States cootained Stites is priocol)ally a high go ade bituminous coal.
SOURCE: U.S. Energy Information Administration, Annual Report to Congress, Volume 2, 1979, p. 120.

TABLE 2
ENERGY SUPPLY AND DISPOSITION BALAN@CE, 1960-1979
(Quadrillion _Btu)________
Activity and Fuel 1960 1961 1962 ]!)(;:1 1964 1965 i9f;f; 1967 190'@ 1969 1970 11171 1972 1973 1974 1!175 IWG 1977 I97X 1979

Supply
Production
Crude oil and lease
condensate . - , 14-93 15.21 15,52 15.! 17 16.16 16,52 17.56 19.31 19.56 20AO 20 0:3 20.01 19.49 19.57 17 73 17.2f; 17.45 18.43 IS.02
Natural gas plant I
liquids - - , - . - - 1.46 1.55 1.59 1.71 1.841 1.88 2.00 2.18 L1.32 2,42 2.51 2.5-1 2.01 2@@il' 2.17 2@37 2.33 233 225 2.38
Natural gaS2 12.66 1:3.10 13.72 1 .1. 5 1 15.30 15.78 17.01 17.9-1 19.07 20.45 2 1, P 22,214 22.21 2" 19 21 21 11). CA 19.48 19 57 19, 49 19. 19
Coal I - - . - 11.12 IW73 11.21 12.15 12.83 13.38 1:1.82 13.93 14.20 15-05 13 59 14.49 I-t37 14.17 1.) 19 15-45 15X; 1 rLO4 I-IAI
Nuclear power 0.01 0.02 0.03 0.04 O@04 0.01 0.06 0 fill 0.1.1 015 0.24 0.41 0.58 091 1,27 1.90 2.11 2,70 2@!H 2.75
Hydropower 1.60 1.65 1.81 1.77 1,89 2A; 2.06 2.35 2@35 2.65 2.63 2.92 2.84; 2,86 :1 18 3. 15 2AW 2:111 2.96 2.96
Oi her I - - (121 (121 (13) O.Ol 0111 001 0.01 0.01 0.01 1) @ O'-@ 0.02 0.02 WJ13 0,05 O.Of; 0.07 0.08 0, 08 0 07 0.09
Total production 41.79 42.27 .13.88 416. It; .18,03 .119.67 52. 52 55AI 5T 1:1 59.41 62.51 61.70 62.81 62. -1: 1G 1. 2:1 60.04; fA I 119 60,30 1; 1 21 G2.SO

Imports
Crude oil 2.20 2.25 2.42 2.43 2.58 D;5 2.62 2.40 2.7f; 2.99 2.81 3.57 .1.71 6.89 7,40 8.72 11.24 14 0:3 13AG 13.!@3
Refined petroleum
products, 1.80 1.94 2.14 212 2.38 2.75 3.01 3.15 3.46 3.91 4. 1;(; -11,97 5.59 G 58 5.73 4.23 4 43 1.73 1.11
Natural gas 0.16 0.23 OA2 0 42 0.4f; W47 0. 50 0.59 0.67 075 0.85 0,96 1. ().'i 11.04; 0,99 098 0.99 1.0-1 0.99 1.27
Other I - 0.07 0.04 0.03 0.03 W07 0.04 0.05 0.05 0.05 0,01; 0.07 0.08 0. 11 0,21 ().:11 If. 19 0.18 0.30 0, .1 .1 O.3s
Total imports 4.23 4.46 5.01 5.10 5.49 5112 6,18 fi. 11) 6.93 7.7 1 8.39 9.5M 1 IAI; 1-1.73 14.42 1.1.11 16 8.1 20.119 1916 111.28

Adjustments I ------- 0.44 -0.62 -0.61 -0.80 - 0.90 -0.74 - V85 - 1.56 -0.71 -OA7 -IAI -OSI - 4151 - 0. .1 @,' - W65 - 1 08 -0.21 - 1 91 - 0.: it; -1.18
Total supply 45.57 46.11 48.29 50.46 52.62 54.85 57.85 60.04 63.35 66.69 69.49 70A7 73,77 76.0 75.00 73,09 7f;.72 78, 1!) W 11 8090

Disposition
Total disposition 45.57 4G. 11 48.29 5 0. 4 G 52.62 54.85 57.145 60.04 (1-3.35 66, IN 69. 49 70.47 73@77 74; G8 75. 0 0 73 09 76@72 78A9 SO 11 8010)

Exports
Coal I - - 1.02 0.98 1.08 1.36 1.34 11S 115 1.35 IAM 1.53 11114 1.55 1 @53 1.45 1 61 1.71) 1.62 1.47 1.10 1.78
Other, - - 0.46 0A0 R40 0.4',l 0 51 OAS 0.50 0.79 0.65 0.62 0.73 (1, W I W61 W63 0.60 0.60 1). r'! 1 0. W i O.Sr. 1. 10
Total exl*rts IAS 1.38 1 48 1.85 1,85 1.86 1.85 2.15 2.03 2.15 2.0; 2.18 2.14 2.07 2.24 2.39 2.VI 2.111 1.95 2.88

Consumption
Itel"ined petroleum
pniducts 11 - 19.q2 20.22 21.05 21.70 22.30 23.25 24.40 25.28 26,98 28.34 29. 52 :10 56 32.95 318-1 33 15 32.73 35 17 37. 14 37,97 X;M2
Natural gas 2 12.39 12.93 13.73 14,40 15,29 15.77 17.011 17.94 I!V21 :@O,69 21,79 VA i 22.70 '2:! @ F) 121 @ 7:1 19 W, 20.35 19.93 20.00 P) 86
Coal 10.12 9.S9 10.17 10.61.) 11.25 1 I,S9 12.48 12.2.1 12. W; 12.7 2 12.66 12.01 12,45 13.30 12.S8 12@14-1 13.73 12.91; M.S5 1@).Os
Nuclear power 0.01 0.02 0.03 0,04 0.04 0.04 O.OG 0 09 0.1.1 0.15 0,24 OAI 0.58 1 f!) 1 1,97 1.90 2.11 2.70 298 2.7 5
Ilvdropower 1.65 1.68 1.82 1.77 1.91 '2.01; 2.07 2,34 2.34 2, 66 2.65 986 2.9 1 3 Of 3.31 :1.22 3.07 2.52 3. 17 :1. W
Oiher 1 ('21 (.,) (11) 0.01 0.01 OAII 0.01 0.01 0-01 0.02 0,02 @).02 0.03 O.Of, 0.06 0.07 Wits O.OX 0.07 0.09
Nei imports
ol'coal coke -0.01 -0.01 - 0.01 -0.01 -DOI -0.02 - 0.03 -0.02 - 0.02 - 0.0.1 0.06 1). 03 - 0. 0: 1 - 0. 0 1 0, Of; 4 10 1 0.02 0. 13 0. 07
Tot a I consu m pt ion .4-1.08 44.73 -16,80 48.61 50.78 52.99 55@99 57-89 (;(.:W G1.53 CGS3 68.30 71 G3 7 1.1; 1 72.7f; 70.71 71-51 76.39 78.15 78.02

Div ton, kouduatural K-
'Hountow,- roal. liizrut@. nnd orith,.6W. -44-otl ;J. -.1. -fu-'a h@ih- vizvlal hu-1 . ......I 16,it@ j! alu Noto
In(ludts imrorts of cruoh- oil for thr Stratcric P,-Iroleufn flesi-e.
Also un lud- inirmirts (it unfinished oils and riniural gns plant liquids.
Incli.id, bit or"I""u'"'al. bgr6ti,. .,it hriiritr. coal coke.: ... it fi,d-j-
A hal--uw 0- In, lud- jock ch-ges. I-, rai.,. roi.elhu-u., blending ...... [email protected] for,oppk-od,luj t-fanll-u ite to U S A,,--d Forr- i,, F I.-
I "cl wh-, cv"d,- oil. refined jw-1 roleurn products, natural it-. voil roke. and bvil'op.w-
16-fined l.-, rldt-unri pioducts @upUlied includv% natural gns plant liquids and crude oil liurnedw% fo-1.
to, lud" R-cration of hydrotpower and net electrit ih inilmn-ts
I- than RAW, qudrilli @ Ifto
N4,(,- Datado not include wi-I di-rived fu4-I con-netl bv the pulpaod jmj.-, i.d,.,Ir, @hivh; ......... Ord t- ... ... ti awd I Hquml,illi .... flou'. MG.A Thi, 1.14'. al,-- lud, , 'ov.1hp.i.Witi- of,,tlu r voj-rr,@ lorrus f- whu 11
-,1,111tent tu,torwal ditto are out [email protected] as sular enrrg,v ublain"t bv the ust-I therroaland phot.-dlau- wind rl:v:;,r,d g-,tlu-t-l bi I th:u, that vh-0-

N,te Suntof 1@ L@ niny not equal total due to indi-l-ideni roooding

SOURCE: U.S. Energy Information Administration, Annual Report to Congress, Volume 2, 1979, page 3.

FIGURE 2

ELECTRIC UTILITY ELECTRICITY FLOW DIAGRAM, 1979
(Billion Kilowatt-Hours)

Imports Exports
21

Residential
680
Coal
1,075

0
Commercial
V)
Consumption 472
C
Uj Production 2,060
Petroleum >.
.0 2,248
304 C

Natural Gas a Industrial
"0
330 0 835

Hydropower
280 Other
73

Nuclear Power 255

Geothermal and Other
4

SOURCE: U.S. Energy Information Administration, Annual.Report
Natu
C
1
0
0
a
7
1
5
Icsid
r
e
8
0
lt@ia
rci
,omme al
472

PetroleL
304
/
drop'
28C

r Povv
Nucleay

to Congress, Volume 2, 1979, page 135. Losses and
Unaccounted For
207

TABLE 3

UNITED STATES COAL TRANSPORT - 1978

Mode Tonnage (1000's tons) % of Total

Rail 323,500 54.0
Vessel
River 96,301 16.1
Great Lakes 16,175 2.7
Tidewater 3,813 .6
Truck (local) 93,530 15.6
Other* 65,893 11.0

TOTAL 599,214 100.0

* Includes on-site movement by means such as conveyors.

SOURCE: National Coal Association, Washington, D.C.

U.S. PROJECTIONS

Because of the diverse and problematic circumstances which affect the
future use of coal, it is difficult to arrive at one projection. The
Congressional Research Service has suggested that a doubling of coal
production to about 1.1 to 1.3 billion tons by 2000 is optimistic but
possible. In its First National Energy Plan, the Department of Energy
projected a tripling of coal production by 1995. The Second National Energy
Plan (NEP II) proj,ects an increase of 150 percent for all uses of coal (direct
use, electrical generation, and synthetic fuels) by the year 2000, assuming a
high world oil price. Table 4 shows the projected increases for coal and
other sources of energy from NEP II. Table 5 describes the economic
assumptions used in developing the projections for NEP II.

The Michigan Energy Resources and Research Association has used a
coal production level of about 2.5 times current production as a base for
projection for Michigan. The Department of Energy projections assume economic
growth of about 3 percent per year, close to the recent average. They also
assumed a lower price for oil than actually occurred. These two factors can
work in opposite directions for examining the projections. if economic growth
is less then 3 percent per year, this might decrease pressure to produce and

use coal. If oil prices are higher, this would increase pressure for coal .
Current economic conditions give little guidance on how to interpret the

extent to which coal use will increase in the future. Coal has and is
expected to increase substantially in its contribution to national energy
needs. This will be dealt with further under Projections for Michigan below.

TABLE 4

TOTAL RESOURCE USE BY FUEL 1975 TO 2000 a
NEP-11 HIGH WORLD OIL PRICED

1975 1990 2000
%Lads PercFn-t J@ads P e r c Fn-t- q!Lads PercFn-t

Total Energy
Consumption 73.7 100.2 118.0c

Coal
Direct Use Plus
@Electricity 15.2 25.5 33.5
Synfuels 0.0 0.2 5.5d
2 21 T5-.7 26 39.0 33

Oil
Conventional Oil
20.4 19.6 16.0
0.0 1.8 3.3
0.0 0.4 2.5
Imports 12.7 15.4 10.3
1 45 7772 37 T2 71 27

Gas
Conventional Gas 18.5 16.9 14.6
Unconventional Gas 0.0 1.5 4.0e
Imports 1.0 2.4 1.7
19.5 26 20.8 21 TM3 17

Nuclear 1.8 3 9.7 10 16.5 14

New Sourcesf 1.6 2 3.2 3 6.0 6

Hydro/Geo 2.7 4 3.6 4 4.1 4

a Numbers may not add to totals because of rounding (does not include coal exports).
b April 1979 projections from SEAS FOSSIL'II program based on NEP-II parameters.
c More recent projections indicated only'109 quads.
d Consists of 2.1 quads of liquid fuels and 2.4 quads of gas final product;
remaining amount includes conversion losses.
e Data not regionalized in Appendix B.
f New source data from TASE scenario (see Section 2.5); includes direct solar,
biomass. and wind.

SOURCE: U.S. Department of Energy, Energy Technology Scenarios for Use
in Water Resources Assessments Under Section 13a of the Federal
Nonnuclear Energy Research and Development Act, July, 1980, p. 5.

TABLE 5

MACROECONOMIC ASSUMPTIONS OF THE NEP-II HIGH SCENARIO*

Growth Rates (Percent)
1977 1990 2000 1977-1990 1990-2000 1977-2000

GNP
(Tri 11 i ons
of 1978
dollars) 1.90 2.92 3.80 3.4 2.7 3.1

Population
(Millions) 216 245 262 1.0 0.7 0.8

Labor Force 94.8** 116 121 1.6 0.4 1.1

Per Capita
Real GN@'
(Dollars) 8,780 11,900 14,500 2.3 2.0 2.0

As projected by the SEAS model using NEP-II assumptions as input.
1975 estimate.

SOURCE: U.S. Department of Energy, Energy Technology Scenarios for
Use in Water Resources Assessments Under Section 13a of the
Federal Nonnuclear Energy Research and Development Act,
July, 1980, p. 10.

TABLE 6

PROJECTED NATIONAL COAL TRANSPORT MODES*, 1985

MODE Million Tons by Mode Percent of Total Moved

1975 1976 1985 2000

EEI BOM NEP EEI BOM

RAIL 418 431.1 503 637 780 608 1,023
65% 63.5% 64.5% 64.5% 65% 64.5% 64.5%

MOTOR 79 89.8 95 120 144 115 193
VEHICLE 12% 13.2% 12.2% 12.2% 12% 12.2% 12.2%

MINE-MOUTH 74 79.2 89 113 132 107 181
GENERATING 11% 11.7% 11.4% 11.4% 11% 11.4% 11.4%
PLANTS

WATER*** 69 69.6 83 106 132 101 170
11% 10.3% 10.7% 10.7% 11% 10.7% 10.7%

OTHER** 8 8.9 9 12 12 11 19
1% 1.3% 1.2% 1.2% 1% 1.2% 1.2%

TOTAL 648 678.6 779 988 11,200 942 1,586

NED - National Energy Plan
BOM - Bureau of Mines
EEI - Edison Electric Institute

Primary Transport mode used to move coal from mine to final destination.
Includes coal used at mine, taken by locomotive tenders at tipple, used
at mine for power and heat; coal transported from mine to point of use
by conveyor or tram; coal made into behive coke at mine; all other uses
at mine; and coal shipped by slurry pipeline.
Includes barge transport on inland rivers and lake vessel transport on the
Great Lakes.

SOURCES: Coal: A Data Book
The President's Commission on Coal, p. 195.
National Energy Transportation, Volume III-Issues and Problems,
report prepared by the Congressional Research Service, March 1978,
p. 58.

PROJECTED U.S. COAL TRANSPORTATION

According to projections by the Edison Electric Institute, the U.S.
Bureau of Mines, and the U.S. Department of Energy for its National Energy
Plan, both rail and water transport of coal are expected to increase their
shares of coal movement only slightly. Rail is projected to increase from
63.5 percent in 1976 to 64.5 percent by 2000, while water transport will to
rise from 10.3 percent to 10.7 percent over the same period. Table 6 gives
projections for all the coal transportation modes.

THE GREAT LAKES STATES RELATIVE TO THE NATION

COAL USE

Measured on a heat content (Btu) basis, the Great Lakes states used
49 percent of the coal used nationally in 1976.. The greatest coal use is
concentrated in Illinois, Indiana, Michigan, Ohio, and Pennsylvania (see Table
7). In recent years, coal use has increased along with other fuel use.

COAL TRANSPORTATION IN THE GREAT LAKES REGION

.Rail is the primary mode of coal transportation in the Great Lakes
region. A substantial portion is transported by water. In 1977, over 39
million tons of coal and lignite were moved to or through Great Lakes coastal
ports and waterways. During the same year, approximately 42 million tons were
moved to or through ports or waterways of the Atlantic, Gulf and Pacific
coasts. (Department of the Army, Corps of Engineers, 1977) See Table 8.

In 1980, the Port of Quebec is expected to handle 500,000 metric tons
of U.S. coal transshipped from smaller lake carriers to larger oceangoing
vessels bound for Europe. The coal is mined in Pennsylvania, shipped by rail
to Lake Erie and then loaded onto lake vessels. In 1979, 50,000 metric tons
moved in this manner through the Port of Quebec. The reason for this
increased Great Lakes-Seaway coal movement is the upsurge in demand for U.S.
coal abroad and the back up at the coal docks along the Atlantic coast.
(journal of Commerce, August 1980)

TABLE 7

GREAT LAKES CONSUMPTION
(Thousand Tons)

2
ENT TA5:@
D EEE S 7 INA T 10 N SHIPHEENT TO SHIP@IENT To FRIOV iz)76 TOTAL

Eec Coke and Re@ . @.) I --- EI e - Coke an i A 11 -,,@
V I Gas Plants Deal Others Total Uti- Gas Plants Others Toa!

NEW YORK 59SO 5157 'a 2405 13562 12004 6408 71-53 25665

P ENNS YL VANI A 37249 21,287, 192 3S70 64592 1462,9 2666-- 19459 Q 1) 7 _@ S

OH I 50i 30, 12505 692 7637 70964 649159 1513i 401SO 1203120

INDiAN4 29239 12@450 363 3785 45637 41279 15786 16388 73453 60.2;

ILLINOIS 35011 2735 537 3172 LIL@55 43556 3596 157148 62qOO

MICHIGAN 21197 4493 2L,8 3857 29805 2@-744 4449 15789 414982 50.92

WISCONISIN 10978 268 308 2017 13571 2C256 278 81-79 28623 112.?,r

MINNESOTA 101-48 6,47 90 1137 12322 20485 842 3586 24913

REGION
TOTAL 200232 61536 2450 27890 292108 271913 73209 1266E, 471804

Includes Industrial Includes industrial. residential, and co=-ercial

SOURCE: COAL: A DATA BOOK, The President's Commission on Coal pp. 34-35

Assumptions for the table above include:

1. Railroads are expected to renain the dominant transport mode through
1985 since long haul movement of coal will increase. By 1985 rail
transport of coal will increase by approximately 2/3 over current
levels.

2. Western rail transport is expected to increase 300 to 400 percent by
1985. Increases in unit train movements are expected, particularly
in the West.

3. Western coal may move by water after it is railed to ports on the
Great Lakes and the Mississippi River. Increased tonnage will be
shipped to Detroit via the Great Lakes, Chicago via the Illinois
waterway, and the South and Southwest via the Mississippi,
Tennessee, and other rivers.

4. No critical problems in terminal /transfer capacity, fleet expansion,
or equipment supply are anticipated through 1985.

5. Major constraints to growth of coal traffic or traffic on inland
waLer-ways are inadequate lock capacity, limited channel depth, and
the age of the Great Lakes fleet.

6. Percent shares of coal transported by primary mode (i.e. moving the
coal most or all of the way from mine to final destination) will
remain virtually constant through 1985: rail = 65 percent; highwa%
= 12 percent; water = 11 percent; mine-mouth generating plant
consumption = 11 percent; and slurry pipelines and other = I
percent.

TABLE 8

SUMMARY OF COAL MOVEMENT THROUGH THE GREAT LAKES PORTS V.
TOTAL MOVtMENT THROUGH U.S. PORTS - 1977

Foreign Domestic
Total Imports Exports Total

United States 211,955,680 1,721,678 53,937,596 156,296,406
Coastal Total 81,569,570 1,721,678 53,937,596 25,910,296
Great Lakes 39,147,171 18,912 16,880,055 22,248,204
(overseas) (Canadian)
Ocean 42,422,511 1,702,766 37,057,541 3,662,204

Coastal Total--refers to traffic from or to both Great Lakes and ocean or
tidewater ports.
Great Lakes --refers to traffic originating or terminating in United States
ports on the Great Lakes system.
Ocean --refers to traffic having a carriage over ocean or the Gulf of
Mexico.

SOURCE: Waterborne Commerce of the United States - Part 5 - National Summary,
U.S. Army Corps of Engineers, 1977.

A substantial volume, 43 percent, of the waterborne coal went to
Canada. Large quantities of coal move from one end of the Great Lakes to the
other, as well as between parts in the mid-portion of the system.

GREAT LAKES INDUSTRIAL COAL RECEIPTS

Industry that receives coal via the Great Lakes fall into six
categories (U. S. Maritime Administration, 1980):

(1) Electric Utilities

(2) Salt Producers

(3) Cement and Chemical Manufacturers
(4) Coal Suppliers and Coke Manufacturers
(5) Paper Companies
(6) Steel/Iron Ore and Automotive Companies

These companies coal use is briefly described below.

(1) Electric Utilities

Five major electric utility companies receive 95 percent of the coal
transported on the Great Lakes. About 1/3 is western coal. Major
western coal deliveries will increase primarily at St. Clair, Michigan (4
million tons by 1985), and Dunkirk, New York. Utility use of eastern
coal will increase by about 2.3 million tons during the 1980's.

(2) Salt Producers

Salt producers use coal to generate electricity for mining. They are not
expected to increase their coal use much in the foreseeable future.

(3) Cement and Chemical Manufacturers

These manufacturers use coal to produce electricity for their operations.
The four firms in this category collectively project a decline in coal
use during the 1980's.

(4) Coal Suppliers and Coke Manufacturers

These coal suppliers and users expect an increase of 1 to 2 million tons
annually by 1985.

(5) Paper Companies

Five paper companies use coal to generate electricity for their
operations. These companies do not project a growth in coal deliveries.

(6) Steel/Iron Ore and Automotive Companies

Because of the current economic situation in the steel and auto
industries and the production of smaller cars requiring less steel,
collective- coal use in these industries is not expected to increase
during the 1980's. However, individual operations may expand while

others contract, indicating that site spec if ic circumstances may be
different from the general situation.

ADDITIONAL DEMANDS FOR COAL IN THE GREAT LAKES REGION

Low-Btu coal gasification will demands for coal transportation in the
region. According to projections of the Second National Energy Plan, under
high world oil prices, the southwest Lake Michigan basin may use up to 7.3
million tons (175.02 trillion Btus) of coal for production of low Btu coal gas
by the year 2000. Industry sources suggest that production of low Btu coal
gas is competitive with other fuels at current prices. This suggests that
additional production of low-Btu gas from coal could occur in the region.

The National Energy Plan's projections do not include specific
sources of coal. Southeast Michigan could be a likely candidate location for
low-Btu coal gas production due to its heavy industry. Coal could be
delivered either by rail or water.

PROJECTED GREAT LAKES COAL TRANSPORTATION

Many projections have been made for Great Lakes shipments of coal.
The projected waterborne coal movement for 1980 ranges from 43 to 106.7
million tons. See Table 9. Earlier projections of 1961, 1970 and 1973
obviously did not account for current circumstances with respect to oil supply
and price. The most recent projection (1976) estimates a volume in 1980--81
million tons--that is twice as large as the volume that was moved in 1977 (the
latest year that information is available for)--39 million tons. The 1980

economic situation in the Great Lakes region would suggest that 81 million
tons is still too high. Given the variability of the region's economy, the
uncertain future of coal gasification, and the uncertainty of continuing
long-term movements of large quantities of coal for export through the Great
Lakes-seaway system, it is difficult to draw conclusions about projected
waterborne coal transport. As the region's economy picks up, more coal will
probably move through the Great Lakes. This study's coal transshipment/
unloading facility review (described below) and a national energy
transportation study (U.S. Department of Transportation, 1980, p. 75) estimate
that if coal shipments increase, coal transshipment facilities will need to be
expanded at ports along Lake Superior, Lake Michigan, Lake Huron, the St.
Clair River, and Lake Erie.

TABLE 9

PROJECTIONS OF U.S. GREAT LAKES SHIP14ENTS OF COAL
(Millions of Short Tons)

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

Corps of Engineers (1) 83.5 93.4 106.7 114.6 124.9 130.3 135.0 139.6 143.2 148.5 --
(1961)
Bureau of Mines (2) 53.0 58.0 62.0 66.0 69.0 73.0 -- -- -- -- --
(1970)
IBLLB - High (3) 61.0 -- 83.0 -- -- 134.0 134.0 134.0
(1973)
00 - Medium (4) 53.0 62.0 74.0 74.0 74.0

- Low (5) 44.0 43.0 43.0 43.0 43.0

Kearney (1976) (6) 81.0 104.5 -- 105.1 149.2 170.5

NOTE: The Kearney projections are for domestic traffic only.
SOURCES: Wisconsin University Sea Grant Program (1976). The Great Lakes TransporLaLion System.
Technical Report 230.
U.S. Army Corps of Engineers, North Central Division (1976). Great Lakes/St. Lawrence
Seaway Traffic Forec,asL Study. Summary Report.

MICHIGAN COAL PROJECTIONS

RECENT USE

Coal in Relation to Other Fuels

In Michigan coal accounts for over 30 percent of all energy used.
(See Table 10). Petroleum accounts for 36 percent; natural gas, 30 percent;
hydroelectric and nuclear, 4.5 percent; and other sources, under 4 percent.
From 1972 to 1977, Michigan's coal use averaged just under 6 percent of the
nation's. over this period, however, Michigan's percentage of national coal
use has fallen from 7.04 percent to 5.09 percent (MERRA, 1980, p.54).

Coal for Electrical Generation and Other Uses

Over the last twenty years, the major use of coal in the United
States and Michigan has been for producing electricity. About 70 percent of
the coal used in Michigan is used by utilities to generate electricity.
Non-utility production of electricity would raise this percentage. The
Detroit Edison Company generates nearly 60 percent of Michigan's coal
generated electricity, the Consumers Power Company generates about 30 percent,
and the remainder is generated by eleven other firms. In the Detroit Edison
service areas alone, about 90 percent of the company's power generation is
from coal . Figure 3 gives an overview of this coal use. Current (1978)
Michigan use of coal is about 29 million short tons.

In 1977, total energy consumption in Michigan was 2,882.8 trillion
Btus. Electric utilities consumed 504.6 trillion Btus, 17.4 of the total.
By comparison, electric utilities' use of fuel oils was 3.2 percent of the
energy used in the state, while utilities' use of natural gas was 1.6 percent
of the total. Currently, 70 percent of the coal used in the state produces 65
percent (504.6 trillion Btus) of the energy consumed in generating electricity
in Michigan. Coal accounts for 27 percent (213.6 trillion Btus) of energy
used by the state's industry. Industry uses 27 percent of the coal consumed
in Michigan; commercial and residential coal users consume less than 1

percent.

Relative to coastal considerations, Michigan receives more coal by
water than any other Great Lakes state. This focuses attentiomon Michigan
shoreline use by future coal unloading and transshipment facilities.
Reinforcing the demand on coastal areas, Michigan has the highest percentage
of electric generating capacity already located in its coastal counties, 88
percent (16051 MWe). Of this, 63 percent are coal facilities, or 55 percent
of its total electric generating capacity. With respect to facilities under
construction or planned from 1980 to 2000, 71 percent (3491 MWe) of the
additional future electric generating capacity will be located in coastal
counties, and 67 percent of this coastal capacity will be coal-fired.

Transportation and D@livery of Coal to Michigan

Rail has been the predominant made of coal delivery to Michigan for
over 25 years. However, water delivery has increased just recently, primarily
due to western coal delivery (see Table 11). In 1975, rail delivery accounted
for nearly 60 percent of the coal shipped to the state. Of this amount, about
83 percent (approximately 50 percent of the total) is delivered to electric
utilities. The remaining 40 percent was shipped by water. By 1979, rail
deliveries approached nearly 53 percent while water was 47 percent, with
trucks, accounting for less than 1 percent.

Over this same time, 1975 to 1979, the proportion of coal transported
to electric utilities increased from 2/3 to 3/4, while total coal delivery
only increased from 31.3 million short tons to 32.4 million short tons. This
increase in utility use was coincident with a decline in coal delivered to
coke plants. One reason for the decline in the production and delivery of
domestic coke and reliance on imported supplies is the environmental
regulations affecting plant location and operation in the United States. This
has shifted the coke sourc,e from domestic to foreigh import. (Communication,

U.S. Maritime Administration)

TABLE 10

PATTERNS OF ENERGY CONSUMPTION IN MICHIGAN 1977
Prepared by the Energy Data and Modeling Division
of the Michigan Energy Administration

E
.2 -a
w C 0
M ::" 0 C
-iE :3 m 5 '8
LL LL Z -; =
0 0
0 LL 72
0 > 0 --F Q) 0
0
1977 a. 0 '0 n Cr LL 0 Uj

USES 1000's Trillion Billions
Millions of Gallons MMCF Tons Btus of Kwhs

Residential 243.2 0 697.1 0 0 940.3 333,651 173 0 0 21.9
(23.2) (0) (96.7) (0) (0) (119.9) (340.7) (4.4) (0) (0) (74.7)1 (539.7)
Commercial 27.0 0 302.8 0 148.0 477.8 171,015 101 0 33.9 16.0
(2.6) (0) (42.0) (0) (22.2) (66.8) (174.6) (2-5) (0) (33.9) (54.6) (332.4)
Industrial 33.0 73.6 154.4 0 180.4 441.4 299,276 8,485 0 79.1 32.5
(3.1) (9.2) (21.4) (0) (27.0) (60.7) (305.6) (213.6) (0) (79@11) (110.9) (769.9)
Transportation 3.0 4,859.6 328.7 218.8 11.6 5,421.. 4,617 0 0 0 0
(0.3) (607.2) (45.6) (29.2) (1.7) (684.0) (4.7) (0) (0) (0) (0) (688.7)
Agricultural 48.6 373 59.9 0 0 14&2 342 0 0 0 .3
(4.6) (4.7) (8.3) (0) (0)-1 (17.6)1 (0.3) (0) (0) (0) 1 (1.0) (18.9)
Electric
Generation 0 0 77.1 0 5W5 633.6 46,174 20,047 128.7 0 --70.7
(0) (0) (10.7) (0) (83.3 (94.0) (47.1) (504.6) (128.7) (0) (--241,2) (533.2)

Total 354.8 4,970.9 1,620.0 218.8 896.5 8,061 855,075 28,806 128.7 113.0 0
(33.8) (621.1) (224.7) (29,2) (134.2) (1,043.0) (873.0) (725.1) (128.7) (113.0) (0)

'hicludes Asphaft, Road Oil, Feedstocks and Petroleum Coke.
All numbers in brackets are shown in trillions of Btus.

SOURCE: Michigan Energy and Resource Research Association, Toward a Unif ied Michigan Energy Policy, 1980, p. 27.

TABLE 11

Shipments of bituminous, subbituminous, and
I-ignite coal to Michigan 1975-1979
(In Thousand Short Tons)

Electric Coke Other Retail
1979 Utilities Plants Industrial Sales Total

All-rail 13,879 674 2,381 30 16,963
Water 10,167 3,352 1,863 4 15,385
Truck 2 - 33 1 36
Total l/ T4,047 4,026 4@,-276' 1-5 32,385

1978

All-rail 13,664 829 1,826 40 16,360
Water 7,527 2,099 1,485 34 11,143
1 - -
Truck 1 104 105
Total l/ T1,192 2,928 3,415 '@_4 27,608

1977

All-rail 13,438 728 2,256 159 16,581
Water 7,721 3,301 1,191 - 12,213
Truck 6 - - 1 7
Total 1/ 21,165 4,029 3,447 160 28,801

1976

All-rail 14,558 922 2,214 224 17,918
Water 6,639 3,571 1,653 24 11,887
Truck - - -
Total l/ 21,197 4,493 3,867 249 29,805

1975

All-rail 15,523 755 2,201 262 18,741
Water -6,279 4,588 1,682 - 12,549
Total l/ 21,802 5,343 3,883 262 31,290

l/ Data may not add to totals shown due to independent rounding
'gource of Data: Form EIA-6, Department of Energy.

FIGURE 3

COAL USE OVERVIEW

MICHIGAN UNITED STATES

COAL USE IN 1974 COAL USE I N 1976

(TOTAL = 29.3 MM TONS) (TOTAL = 665.0 MM TONS)

ELECTRIC ELECTRIC
RETAIL GENERATION RETAIL GENERATION
DEALERF DEALER,S'
(I %) _ (71%) (67%)
ALL ,.@EXPORT
OTHER (9 %) AL
(15%) OTHER
COKE (I %) COKE
(130/0) 1 (12%)

(23%)
INDUSTRIAL INDUSTRIAL

MICHIGAN COAL USE MICHIGAN COAL USE
CHANGE IN COAL CONSUMPTION
FOR ELECTRIC GENERATION
PATTERN, 1957 - 1974 13Y COMPANY 1974
100
90 ELECTRIC (TOTAL 20.8 MM TONS)
80 UTILITIES
-j 10 DETROIT
60 EDISON
0
1 (58%)
DU
w ALL
0 40 cot OTHER
(I CONSUMERS
30 ALL POWER
20 OTHERS

1957 1967 1977
EL ECTRIC

G_NER AT 10N

67
@EXPORT

AL L
OT HERS

SOURCE: Michigan Energy and Resource Research Association, Toward A Unified
Michigan Energy Policy, 1980, p. 128.

While transport mode is determined mainly by cost, other factors also
affect it. It is cost-effective for western coal to be transported by rail to
Superior, Wisconsin, and then by water to Detroit Edison facilities at St.
Clair . However, at the Monroe plant water delivery is dictated by power plant
operation. At that facility, rail unloading capacity and track holding of
rail cars for high-sulfur coal from Kentucky is limited, so low-sulfur coal
from Kentucky is moved by rail to Toledo and then by water to the power plant.
The transshipment at Toledo makes the transportation cost of the low-sulfur
coal more expensive. The two types of coal are blended at the power plant to
meet air quality standards.

Figures 4 through 6 show the incidence of coal movemrnt in the state.
The predominant movement and delivery of coal occurs in coastal areas.

Source of Michigan Coal

Eastern Kentucky provides about 38 percent of the coal used in
Michigan. Other sources of coal for Michigan are Ohio, West Virginia,
Virginia, Illinois, Pennsylvania, Wyoming and Montana. Western coal (from
Wyoming and Montana) use in Michigan rose from 4 percent in 1973 to 12.3
percent in 1979. (MERRA, 1980, p. 25).

MICHIGAN PROJECTIONS

Review of Projections and Assumptions

Several projections have been made for Michigan's coal consumption.
In 1976, the U.S. Bureau of Mines projected that Michigan would consume 36.0
million tons in 1980 and 61.5 million tons by 1985 (U.S. Bureau of Mines,
1976), a projected increase of 71 percent in five years. The Bureau of Mines
1980 projection will probably be about 5 million tons too high, given 1978
coal consumption to be 29.0 million tons, 1979 coal deliveries of 32.4 million
tons, and the effects of the recession on energy use by industry in 1980.

FIGURE 4
MICHIGAN RAIL NETWORK
MAJOR COAL ROUTES - 1978

Marquette

Sault Sto. Madia
3iod
7

Iron River*

Iran Mountain
OF @LACKINAC
>Chebovgen
$=nabs

01C MICA, ey
P

menomnQ10 Alp
OF TA

Trav city

FRANKFO

LIJOINGTON
Bay
@IDLAND City
Mt. ESSEXVILLE

VC Saginaw

Musk- --Part
Iin Huron

Grand Rapids
W. OLIVE
A N;'Sr IN
CONNO

K- Jackson Ann .@IVER ROUGE
Bards
Benton Harbolf Creak Arbor TRENTON
MONROE

ERIE

FIGURE 5

COASTAL COUNTIES RECEIVING COAL BY RAIL IN 1975
(In Carloads)*

WAYBILL COAL DESTINATIONS IN MICHIGAN

...........

...............

PLANNING SERVICES
DIVISION

Rail Carloads

2-0000. 999999.

..........
10000. 20000.

..........

5000. 10000.

1000. 3000.

......... ....
1 1000.

.... .......
0.

..........

One carload equals one hundred tons.

FIGURE 6

COASTAL COUNTIES RECEIVING COAL BY WATER IN 1975
(In Carloads)*
1975 CORPS

vi I G q

PLANNING SERVICES
DIVISION

Rail Carloads

10000. - 999999,

.. ........
FM 5000. - 10000.

3000. - 5000.

1000. - 3000.
El 1. - 1000.
F-1 0. - 1

1 Carload equals one hundred tons.

The Michigan Energy Resources and Research Association report "Toward
A Unified Michigan Energy Policy" is the best source for energy projections
for Michigan. Based on national coal production, the Association projects
coal use by the year 2000 to be 37 to 47 million tons/year for electric
utilities, 10 to 20 million tons/year for industry, 5 million tons/year for
lake, and 5 million tons/year for synthetic fuels. The projections total
about 67 million tons/year. The assumptions on which these projections are

based include:

1. National coal consumption will be between 1200 and 1800 MM tons by
2000. Probability is low of extending much beyond this range.

2. Michigan coal consumption will increase proportionally to national
coal consumption. This assumes that Michigan can diversify its
industrial base and/or retain its status as a major industrial
state.

3. Industrial use of coal (expressed as a percent of the total coal
use) will range between doubling and halving its current percent of
total coal use by the end of the century.

4. Synthetic use of coal will be about 10 percent of coal use
nationally, and 7 percent of coal use in Michigan by 2000. Due to
major roadblocks, primarily in a financing, coupled with long lead
times for the development of a viable synthetic industry, the
current estimates of our synthetic fuel prospects are down
considerably from estimates made a few years ago.

5. The use of coal for coke for steel making will remain steady or
increase moderately in absolute terms ' but deciine somewhat in
percentage terms by the end of the century.

Evaluation of Projections

Overall, these assumptions appear reasonable. However, specific
information behind the assumptions points to ways in which extrapolation of
national trends to Michigan may be inappropriate. First, Michigan currently
uses a higher percentage of coal for its overall energy needs. Nationally,
coal supplied 17.7 percent of the energy consumed in 1978. In the same year,
coal supplied 26 percent of Michigan's energy needs. Electric generating that
uses coal as its principal fuel in Michigan accounts for 61 percent of the
state's capacity. Additional coal-capable units account for less than 18
percent of Michigan's electric generating capacity. However, elsewhere in the

United States, the percent of coal-fuel generating capacity is lower, such as
in New York with 12 percent, and the coal-capable capacity is higher. This
suggests that Michigan may not have the flexibility or capability to double
coal use in electrical generation, which is the largest coal using sector.
However, focusing on capacity alone can be misleading since the most efficient
generating units are used to meet demand at any point in time, and power is
bought from and sold to power companies outside the state. Coal is used to
generate about 70 percent of the electric power in Michigan. (MERRA, 1980,
p.28)

Additional information also provides insights into this situation in
Michigan:

ENERGY-USING SECTOR MAJOR ENERGY SOURCE(S) % OF SECTOR'S ENERGY
NEEDS - 1977

Transportation Petroleum Products 99 %
Agriculture Petroleum Products 93 %

Residential Natural Gas 63 %

Petroleum Products 22 %

Commercial Natural Gas 53 %

Petroleum Products 20 %

Industrial Natural Gas 40 %

Coal 28 %

Electric Utility Coal 65 %
Hydro and Nuclear 17 %

Energy consumption in Michigan in 1977 was 2882.8 trillion Btus. The
industrialand electric utility sectors together account for 45 percent of the
state's total. In these two sectors combined, coal constitutes 55 percent of
their energy consumption and 99 percent of all coal used in the state. As
noted elsewhere, coal provides nearly 70 -percent of the energy used by
utilities.

It appears that the wide range of assumed industrial use of coal
(MERRA, 1980) above is due to uncertain and divergent courses of action in the
future: (1) a halving of industrial coal use might be due to conservation and

cogeneration, and (2) a doubling of industrial coal use might be due to boiler
conversion from oil and gas to coal . However, a recent study (U.S.
Environmental Protection Agency, 1980) reveals that few industries will
convert to coal over the next 20 years. These trends are expected to

continues.

Michigan coal-fired electric generating capacity is 11,161
megawatts. Coal-capable generating capacity under construction or planned to
the year 2000 would increase this by about 50,percent over the next twenty
years. This clearly suggests that Michigan coal-fired electric generating
capacity will not double by the year 2000. Taking into account that (1)
enforcing coal conversion orders is less than 100 percent due to exemptions
and the economics of each case, (2) the capacity of the power system is 70
percent due to reserve requirements and operating capabilities, and (3) a long
lead time is needed to bring generating plants on line, Michigan utilities
probably will not double coal use as projections would indicate. This
conclusion is more significant because electrical generation is the major coal
user in the state. With current high costs of converting from oil and gas to
coal, and other factors outlined in Appendix E, other industries are not
expected to quickly convert to coal. Thus, Michigan will probably not move
with the rest of the country in doubling coal use by the year 2000, unless
major increases are made in other industrial sectors. A more reasonable and
practical estimate is a 50 percent to 75 percent increase by the year 2000.
However, the revised Second National Energy Plan projects about a 150 percent
increase in total coal use by the year 2000. This would be consistent with
MERRA's methodology.

Other industries do not expect to expand their coal use substantially
in the foreseeable future. Over time, as production increases, coal use will
increase, but the extent is not clear, particularly with the state's dominant
auto industry producing small cars in many locations outside Michigan. Thus,
future coal use by other industry in part stems from the business climate the
state provides by tax and employment compensation laws and by labor
initiatives . At this time, it is difficult to determine which direction these

will take and what the results will be for coal use.

Industries' future demand for coal can be both (iirect and indirect.

The indirect demand might be in the form of synthetic fuels. While not
projected by the U.S. Department of Energy, southeast Michigan could be a
likely candidate location for low-Btu coal gas production due to its heavy
industry. If gasification facilities were built in southeast Michigan, would
probably result in the construction of additional coal docks. The probability
of this occurring is not certain, but several proposals for producing
synthetic gas from coal have been made in the Great Lakes region.

COAL TRANSPORTATION IN MICHIGAN

Water: Michigan's Connecting Channels and Locks

The Great Lakes connecting channels and locks for waterborne
commerce in the upper Great Lakes are all in Michigan's coastal zone. They
include the St. Marys River and the Sault Ste. Marie Locks connecting Lake
Superior and Lake Huron, and the St. Clair and Detroit Rivers which, along
with Lake St. Clair, connect Lake Huron and Lake Erie.

Coal represents nearly one-fifth of the tonnage transported on Great
Lakes waterways. From 1975 to 1978, domestic coal movement on the Great Lakes
increased by 1.2 million tons from 21.8 to 23.0 million tons. In 1978,
eastern coal was 87 percent of the domestic waterborne coal traffic, with
about 85 percent loaded at Ohio facilities and the rest at Chicago. The major
western coal movements are 'rom Superior, Wisconsin, to St. Clair, Michigan,
and to Marquette, Michigan. Coal delivered to Port Huron has increased from
1.1 million tons in 1975 to 2.7 million tons in 1979. An additional 4.0

million tons is expected by 1985.

Most coal on the Gr2at Lakes which is delivered to Michigan moves
through three connecting channels all located along Michigan's boundary with
Ontario. These channels are: the St . Marys River, the St . Clair River and
the Detroit River . Over the last 25 years, the peak combined tonnage moved
through these waterways was about 49 million tons in 1966. From 1973 to 1977
the coal tonnage has been relar.*vely stable at 33 to 34million tons annually.
(See Appendix B) The 1977 tonnages are given below:

Waterway 1977 Tonnage (short tons)

Detroit River 12,891,683
Gray's Reef Passage 417,880

Keeweenaw Waterway 73,844
St. Clair River 11,405,652
St. Marys River 85205,491
TOTAL 32,994,550

The largest increases are expected through the St. Marys River and
the St. Clair River as western coal use increases by 4 million tons between
Superior, Wisconsin and Detroit Edison's facilities along the St. Clair River.
However, if coal gasification occurs in the western Lake Erie Basin, more

eastern coal may move through the Detroit and St. Clair Rivers to supply this
potential demand.

Currently, vessels in the 1000-foot category carry the coal that
moves from Superior, Wisconsin, down to the Detroit area. The connecting
channels (exclusive of navigation locks) do not have capacity limitations for
projected coal movement by vessels in the 1000-foot category or smaller to the
year 2040. This is the case even with coal movements combined with pr'ojected
movements of other commodities and goods. Due to channel configuration,
vessels in the 1200-foot category would begin to constrain capacity through
the St. Marys River if the Sault Ste. Marie locks could accomodate them by the
year 2000, due to expected slower navigation in turns of the St. Marys River
required for vessels of this size.

The Sault Ste. Marie locks will have capacity limitations by the
early 1990's. For all commodities, assuming (1) a growing economy, (2)
nine-month navigation season, and (3) that all waterborne coal is transported
by larger vessels which must use the Poe Lock, the locks could reach capacity
by the 1990's. A more slowly growing economy would put this date off several
years. However, Corps of Engineers projections, even with this capacity
constraint, provide for a growing movement of western coal from 17 million
short tons in 1980 to nearly 31 million tons in 1992-93 passing through the

TABLE 12

SAULT STE. MARIE (SOO): UNCONSTRAINED TRAFFIC, LOCK CAPACITY,
TONNAGE LOST,, TOTAL TRAFFIC BY GOMMODITY GROUP
(thousands of short tons)

I "r 3

1980 1987 199n 1992 1993 1.995 2000 7020 20loO

Total Soo Traffic
9 M01101 Base
iou Fos Lock 103,832 1.12,914 117,765 1-2 6, -jgT-
uncongLralned Demand 82,640
Lock Capacity 120,-074.- 120,071, T)-7 F- ---- TJ-1 7@-- -j'7-
120-,0-7-4-- 120,074 1.20,074 1.2(),
To"na e Lost IT 1,0
Soo Other Loocks
Unconstrarned Demi-I 42,081 48 529 50,947 52,739 53 634 55,425 59,903 76,780 95 868
Lock Capacity 43,IZ9 7. 1! 7 21
696 16,174 52, 1 110
41 jr9pnoge Lost
to Mo"th Tce Free Operntimml Min
i0o
Yncongtrnined Den-ind 8 104, 7 16 113,858 118,746 ---F2-1-,190 -T-26-, F)79---- --F3V, 2W--- "5 -11---- 7-8 -R]",
Lock Capacity 135 592 -@5 -i9@ 5@2 135,592 J.35 92 135,592 135,592 135,59Z 1,15"),02
Tonnage Lost
,oo 2ther,@cka
U., - -3y@@JT- -Tj- j707- 7
_...tr. d Dematul 4 3, Tr.= 'T
Lock Cnpaclty 51_,,009 51 '60-9 51 009 - 51 51,io-')-9 -51.,UU9__ 5 1., (L9 51,009 51,m)q
Tonnage Lost 510_____ 3 2 1 -3,231 5,05-2 9 603, 26, 8 17 46,231

12 M011th Pin"
Soo Poe Lock
Wconstrained Dema aid =3 R 7 04, 1@ 1,19,703 122,1614 127,088 139 400 196,168 2 0 1 , 00 2
Lock Cap city 135,592 135,59Z 159,9-46- ---1-5-9,-94-6 ---)-59,-946 159,946 15t),7P@6--- T-',T)- -1 -Y-j-
_I@vomage Lost - )6,1122 LUI 056
�oo Other LoSka
21
Unconstrained Demnnd __@L9, 06 1 1 54 510 5 1, @, L@7 7,@--- 62,006 J j-- AY,-- -T-) , 9-3 2--
61,454 61,454 61,431, 61,454 61,451,
Lock Capacity 5A
Tonnage Lost - 55Z 1 ,171 '17Tv-

TABLE 12 (Con't)

2 of I

1980 1987 1990 1992 1993 19911 2000 2020 2040
lr,,:, Ore...
9 p .. t r,
.Soo floe -[;O-CT
Uncollstrai"ed Demand _83,_f;_71__ 87,141 138,01- -9 -2 T-3 6- 100,996 v""s"O
Lock Capacity 89 098 89 89 098 89 098 89 098 89,()98 89,098
89,098
Tonimae Lost - 3,238 11,898 _)5,75?___ JIFF,_311-
tO Mont), Ice Free Operitionn) Han
Soo Poe Lock
uncullstraltied Demand 66, z.rT-
Lock Capacity 100,152 IOOJ52 101,152 __101 2 101,152 10 _,J@52 lot 152 J,()j t52
10
Tonnage Lost
4 62 0 3 10 2,.-1.2 1.

12 Month Plan
500 Poe Luck
Uticonstralned Demand 976 84,760
741 _20, 50-3 __?4,028 102 81#1 .14 7, 51.6 204,116 -
Lock Capacity 100,152 100 152 117.563 1IL563 ___LI7, 63 7 1!1263__ 1, 1 7.,_ 5 61-
Tonnage Lost 29,953 86,553

9 Motith Rage - -----
_Soo 110C lmcl
Unconstrained Demand 17,038 -25,577 29,237 30,624 31%-jig- j2-,- 705 36,173 1,8-,721 - 5-6, t58-
30-,9_76- --- 30,976 J(),916
Lock ;apacity 30,976 30,976 30,976 30,97 30,976 30,976
Tonnage Lost - - - -1 T.T_ --1-, -7 79-- 5,191 --11-, 7T.-, - 25,182

tO Movith Ice. Free. Operat I.oiml lIhm
Soo Poe Lock
Unconstrained Wmand 11,175 25, 40 32,896
29 05
411 30 8 31 502 36 381 49 012 56,562
Lock Capacity. 35 @40 35,440 __15, L.4. 0
_j5 35,440 35 440 35,440 35,440 35,/sm)
440
Tonnage Lost - - 9141 @13,572 21,122

12 Month Ft.-m
Soo Poe 1,(wk
Unconstrained Demind tl,l j 30,962 it-, 661---- --33,06
_0 __)_6,559 56,8-86
IA)ck Capacity 5 440 -1-5. 440--_ _4_2 31@ 3_
Tonnage Lost __14.5_03 __

TABLE 12 (Con't)

1980 198 7 .1990 1992 1993 1995 2000 2020 '.?0/,()

Gral n
2 Month Base
goo Other Locks
Node Total LT 146 27 0146 27 01#6 2 046 27 01#6 Z7 046 27,0146 2 7 0146
10 Month 1. cc kree Operational Ptan
Soo Other r.7
Node Totals 27,669 28, -28, @44@- 28,93-7 ---28,T8- 9,6 q---

12 Moth Plan
Soo Other 1A)cks 32,624
28 68t
140de Total i 9 30,1 6 30,786 10,835 3 @IT6 4- 31,609 32,390

GENERAL CARGO
7 tionth BasZ7-
t_n 'goo other Lij(*-7k-.g-
-Node Total 19T- 204 204 204 294 204---- 204

10 tiontil tce I-rev. Operattollal PU11)
Soo Other Locks
Wde Total 200 226 233 239 2 4 -2 201s- -277 2 77-

t2 fluitth Plan
Soo Other Locks
Node Total 200 266 --266 269 284 --2-91)--.--- 392

NOTE, Tile current format of tile caparfty modef ontpot doen not permit allocativii of capavity and tonnape I os t
for tile three tricks at tile Sno which are smaller than the Poe Lock.
Tile ass a I. iron ore exc I its Ivel y
. jimption behind tile Cap,(, Iltv analysts is that tile Poe Lock Is reserved for Co, And
Atthotigh qomn coal. and Iron (ire are assiimed to pass through tile three smaller tocks tile amonnt ts abolit
10 million tons or l.eqr. and is not broken out tn the Coal and tron ore toLats.
Attliongh tile totat Soo Capacity ts held co".qtint inider tile "Lock Capacity" ltne on the'rotai. rwo 'rraffit.
analysts, there ts continned prowth tit tile General Carpo. commodity Rroop with tile asqlImption Lilau Croleral
Cargo displaces some. lesser vattie bnIk commoillties (thus accotinting for tile prowth of GC front 766 to 1133 (in tile.
last line of tile tal)119

SOURCE
U.S. Army Corps of Engineers, 198().

locks. A ten-month navigation season would extend the time of capacity limits
at the lock to about the year 2000 and could permit over 35 million tons
through the locks, doubling estimated coal traffic in 1980. Year round
navigation would extend the capacity limit to about the year 2010 with a
throughput of over 42 million tons. Table 12 provides details of these
projections.

Some interesting implications for coal movement in connecting
channels result when assumptions about specific commodities are varied. if
the future demand for iron ore levels,off to the projected 1987 level in Table
12, about 10 million tons of capacity are available for other commodities,
which could include coal. The reason for emphasizing coal here is that it is
assumed that vessels hauling both coal and iron ore would be larger to take
advantage of economies of scale. In any case, more coal could be moved on the
upper lakes sooner, or the year of capacity limit of the locks could be
extended for coal (or other commodities) beyond 1995 or even the year 2000
depending on the growth in demand for the commodities. This could be done
without extending the navigation season. However a ten-month navigation
season (which is not totally out of the range of possibility even without
major navigation assistance such as icebreakers) could extend the capacity
limit for a growing coal demand (combined with other commodities) well beyond
the year 2000 if iron ore leveled off at the projected 1987 level of Table 12.

Thus, doubling western coal movement from the Duluth-Superior harbor
area down the upper Great Lakes could be accomodated without major structural
changes in the navigation system or major season extension (some routine
icebreaking might still occur in to ensure normal levels of commerce in
harbors). Dock handling capacity in Michigan could also accomodate such an
increase if this additional coal were delivered at docks throughout the state
and not concentrated at one location. (See Appendix C.) This is significant
since Corps of Engineers and Coast Guard programs in Michigan's coastal areas
must be consistent with Michigan's coastal management program. This analysis
would suggest that the navigation system outside the harbors could accomodate
increased coal movement over the next twelve to twenty years without a major
policy conflict over season extension. Depending on the growth in demand for
western coal, plans to accomodate coal movement through the locks beyond the

year 2000 need to be prepared in the early 1980's because of the long lead
time necessary for evaluation, design, and construction of structural changes
and power plants and the establishment of markets for coal. [Note: The
Detroit Edison Company, in its long-run projections, has assumed that in the
1980s reduction in electric demand in the auto industry caused by reduced
steel use in the down-sizing of cars will be offset by increased demand for
smaller domestic cars. Thus, this assumption of an electric utility is
consistent with the possibility of a leveling of iron ore demand, assuming
that most iron ore is used to produce steel for the auto industry.]
[Assumptions for lock capacity: (1) 85 percent of maximum practical capacity
with 24 hour operation and (2) capacity limit is reached at 6 hour delay per
vessel.] Compared with other commodities moved on the Great Lakes, coal is
relatively stable. The wide fluctuations of iron ore and grain since 1972
could provide a margin for expanded coal movement through the locks to and
beyond the year 2000. This would also apply to the Welland Canal and the
Seaway locks.

A large percentage of ships now use the Poe Lock, which is the
largest lock at Sault St. Marie. The capacity limit for coal and other
commodities at the Sault Ste. Marie locks could be further extended if coal

were transported in smaller vessels through the other smaller locks at the

Soo. These vessels would be in the 600- to 700- foot class. Unless no other
low cost transport alternative existed, domestic receivers of coal would
probably not use this possibility because larger vessels offer economies of
scale. However, if the Poe Lock were temporarily not available due to a
circumstance such as extended maintenance, traffic would have to be diverted
through the smaller locks. This would mean that more transits would be made
by smaller vessels through the smaller locks. Since the larger vessels carry
western coal to St. Clair, Michigan, such a consideration may be important in
the planning and cost of western coal delivered to Michigan in the future.

However, smaller vessels could serve the international trade in coal
because they could navigate the Welland Canal and the St. Lawrence River, and
consolidate their cargoes on larger ocean-going vessels at ports along the St.
Lawrence River below the Seaway locks. Reducing shoreline effects from vessel
passage would mean larger vessels making fewer transits of the connecting

channels. But, if international demand for western coal shipped through the
Great Lakes-Seaway system occurs, capacity at the smaller Sault Ste. Marie
locks may not be available as soon as the late 1980's, according to the
projections of Table 12. This traffic would have to compete with vessels
serving domestic demand using the larger locks.

This situation assumes three additional factors: (1) that foreign
demand for western coal will be served by traffic on the Great Lakes seaway
system, (2) that larger (1000-foot) vessels will not be used to serve foreign
western coal demand - involving two transshipments within the system in
addition to the original -loading and unloading due to vessel size constraints
of the Welland Canal and the St. Lawrence River and (3) that the Welland Canal

and St. Lawrence River have the capacity to serve this international traffic.

The Welland Canal is an obstacle in this international movement. For

most purposes, the capacity of the Welland Canal has been reached. The
Canadian Seaway Authority is attempting to increase its capacity through
shunter service and all-weather navigation aids. However, if Canadian demand
for iron ore is dampened or cam from a source beyond the seaway and the
capacity can significantly be increased by these methods, capacity for several
hundred thousand tons of coal could exist. Furthermore, lower Canadian demand
for iron ore would also reduce a demand for eastern U.S. coal by the Canadian
steel industry. The Welland could then be used to transport this eastern or
the western coal to other foreign markets.

The St. Lawrence River locks can accomodate several million tons more

of coal export movement. As on the Welland Canal, since this capacity could
be available throughout the year and not limited by times of peak demand
(e.g., grain movement in the late fall), such coal export traffic should not
be a problem. (Communication: St. Lawrence Seaway Development Corporation,
August, 1980) European coal users are placing increasing emphasis on sulfur
dioxide control, which could increase the demand for western U.S. coal and low
sulfur eastern coal. The European concern stems in part from a desire to
reduce problems caused by acid rain. In 1979, 50,000 tons of Pennsylvania
coal were exported out the seaway and in 1980 another 500,000 tons are
expected to be shipped via the seaway to Europe. Contacts with public and

private agencies and organizations indicate that the use of the Seaway for
coal transport, including consolidation of small loads to larger vessels, to
other foreign markets has not been as seriously evaluated (as it should be).
However, as coal washing (to remove sulfur) technology improves and its cost
is reduced, and is competitive with eastern and long-distance transported
western U.S. coal, use of local coal in Europe and elsewhere may reduce
projected demand for eastern and western U.S. coal. Furthermore, the
competitiveness of the Seaway for transporting U.S. coal for export may depend
on the stability of tolls on the Seaway.

It is possible that more eastern, and perhaps western, U.S. coal
could move through the Great Lakes-Seaway system to foreign markets. Over the
next ten to twenty years, this could be accomplished without a formal
navigation season extension. If western coal was the source, Michigan's
connecting would experience more vessel traffic and added shoreline erosion.
The extent of erosion is not possible to evaluate within the scope of this
study; it may be minimal. In any case, it would be difficult to separate the

effects of increased waterborne coal traffic from those of other waterborne

c ommerc ial traf f ic .Fortunately, much erosion can be controlled by enforcing
speed limits, in connecting channels. Also, larger vessels making fewer
passages would reduce the potential for such a problem. Benefits to the
region, nation, and even Michigan would need to be evaluated in the context of
lower oil imports, more reliable domestic fuel sources being available, and
overall lower fuel costs in the near and mid terms by using coal instead of
expensive foreign oil. If foreign demand for U.S. coal moving out the Seaway
is significant, planning for expanding the Seaway's capacity should as soon as
possible due to the constraint at the Welland Canal.

Rail Lines

The greatest concentration of rail transport and delivery of coal in
Michigan is along the corridor from Toledo, Ohio, to Detroit, Michigan. This
rail corridor also moves many other commodities and goods. Assuming even a
modest growth in other commodities and goods in the future, this corridor
could handle well beyond a doubling or tripling of coal movement, even under
current conditions. (Communication, Michigan Department of Transportation).

Other locations in the state receive substantial volumes of coal by rail (as
indicated in detail in Appendix C, "Review of Coal Unloading Facilities").
Rail lines serving these locations also have considerable unused capacity
available for coal transport. overall, rail transport capacity will not
constrain future coal delivery to Michigan's coastal areas during the next 20

years.

Truck/Highways

Less than half of one percent of the coal shipments to Michigan come
by truck. Most intrastate movements are twenty miles or less. The principal
continuing movement of coal by truck is the transfer of coal from the
waterside receiving dock of the Traverse City Light and Power Company on Grand
Traverse Bay to the electric generating plant in Traverse City. Overall,
highways have sufficient capacity to handle large increases in coal movement
to Michigan's coastal areas, subject to weight and axle limits. Local
conditions may restrict certain coal truck movements.

PROJECTED LOCATION AND TYPE OF COAL TRANSSHIPMENT

FACILITY EXPANSION AND DEVELOPMENT

Coal transshipment facilities in Michigan will need expansion to
accomodate increased coal movement in Michigan. To determine additional
facility needs, companies, dock operators and port managers were contacted.
Questions were asked concerning (1) known or perceived future coal demands for
the facilities, (2) the origin and transportation connections of the coal
moving to the facilities, (3) use and capacity of existing facilities, and (4)
expected facility changes to handle future coal deliveries. The results of
this coal transshipment facility needs review are in Table 13. The complete
results are included in Appendix C. Figure 4 is a map of Michigan showing its
planning regions refered to in Table 13.

TABLE 13

LOCATIONS OF INCREASED COAL DELIVERY AND
PROJECTED COAL UNLOADING FACILITY
EXPANSION AND DEVELOPMENT
IT MICHIGAN COASTAL COUNTIES

POSSIBILITY FOR
REGION/COMPANY/CITY FACILITY EXPANSION TO BE DELIVERED BY TIMEFRAME

Region I
* Detroit Lime Co. Yes Lake Vessel 1981
-Detroit, MI

@ Detroit Edison Co. Not Needed Lake Vessel (Rail)
-St. Clair, M1

Region 7
o Detroit Edison Co. Yes Lake Vessel
-Harbor Beach, MI

Region 10
� Morton Salt Division -- Lake Vessel 1980-1985
-Manistee, MI

� Traverse City Light
and Power No Lake Vessel 1983-1993
-Traverse City, MI

Region 11
C. Reiss Coal Co. Not Needed Lake Vessel 1980
-Sault Ste. Marie, MI

Region 12
� Delta Coal Dock Yes Lake Vessel
-Gladstone, MI

� C. Reiss Coal Co. Lake Vessel 1980
-Escanaba, MI

� Marquette BOard of
Light and Power Currently Expanding Lake Vessel 1982
-Marquette, MI

Region 14
Verplank's C%al
and Dock Co. Yes Lake Vessel 1981
-Ferrysburg, MI

TABLE 13 (Con't)
Region 14 (Con't)
a Grand Haven Board
of Light & Power No Lake Vessel 1983
-Grand Haven, MI

Consumer's Power No Lake Vessel 1983
-Muskegon, MI

e Consumer's Power No Rail 1980
-West Olive, MI

These facilities are expected to operate under the "coal brokerage" concept.
They will receive coal, store it, then load it again for further transportation
in smaller volumes to individual purchasers.

A Note on Coal Use by Lake Vessel. While coal as a fuel for vessel
transport has received renewed interest nationally, in the Great Lakes region
it is not clear what the future of coal is as a fuel for the commercial water

sector. If this use of coal again becomes significant, more locations around
the Great Lakes will be used to unload, load, and store coal for lake vessels.

Conferences addressing coal as a significant marine fuel again in the
future have reached "general agreement that (1) oil may not be available on a
business as usual basis for ship bunkering in the near future, (2) it [oil's]
quality is deteriorating rapidly, and (3) it is important to consider alternate
fuels including coal and coal derivatives immediately." (Cleveland-Cliffs Iron
Company, 1980) The Cleveland-Cliffs Iron Company is considering construction
of a 1000-foot Great Lakes bulk carrier with boilers to be fired by either coal
or oil . (Cleveland-Cliffs Iron Company, 1980) Currently, nine Great Lakes

vessels use coal.

SUMMARY

Coal use in Michigan will increase, particularly in coastal areas.
Coastal locations using coal are primarily served by water and rail transport.
Thirteen coastal locations will increase deliveries of coal and five of these

will require coal facility expansion during the 1980s.

FIGURE 7

MAP OF MICHIGAN'S REGIONS

Central Upper
Peninsul 10
13
.CE Eastern Upper
-04" 15cootca-, Peninsula Region
Western 12 -CKWA
Upper Peninsula Region DtLIA

Northeast Michigan
@esouf s,, Council of Governments

Northwest Michioan Region, 10
I....... c,*"o,o olcoo^ 7"co",

.-IsTel Wo.o
I .--L. I CI-E IrIA-" East Central
West Michigan Region 7 Michigan Region
act... -(cost. I 's..LLA
--o-c- :;4A Io SA.11C
West Michigan
Shoreline Region
ST CLA.

ACO

Southeast Michigan
Council of
Governm
ents
Southwestern
Michigan Region
CA- .1!166@i

SECTION III

EVALUATION STRATEGY AND GUIDELINES

Section III

EVALUATION STRATEGY AND GUIDELINES

INTRODUCTION

To evaluate proposals for coal unloading facilities in Michigan, a
systematic approach is needed. On a site specific level, problems of land use
in small communities and dust generation may be important, though overall the
effects of coal transportation and unloading are expected to be minimal. The
impacts of these activities however still must be viewed from a larger
perspective of their significance in the coal production and consumption cycle
and in the overall goods and commodities transportation system. Criteria for
assessing the effects of mining coal and judging their relative importance

must be considered.

COAL PRODUCTION AND CONSUMPTION CYCLE

The coal production and consumption cycle includes: availability of
coal resources, demand for coal, mining/extraction, transportation, energy
conversion, and consumption/end use. Most problems have been identified at
the mining/extraction and conversion steps. Advances in reclamation and
stronger state and federal laws have reduced mining-related land damage. With
respect to conversion, most experts agree that reducing sulfur levels further
in coal preparation and combustion is both technically and economically
feasible. This will help mitigate the major problem with coal use -- sulfur
dioxide emissions.

With respect to transportation, steps are taken in loading coal and
handling it on site that reduce dust generation, such as washing coal before
loading it at the mine, locating and shaping coal piles to reduce wind-blown
dust, and placing straw on storage areas. Coal is inert, so any dust
generated is more of an aesthetic problem than a chemical or biological
concern. Water transport offers the least chance for coal dust generation
since the holds are covered. Rail cars are uncovered but most coal is wet

when loaded which reduces dust. The project staff observed coal being
unloaded, transferred from storage to conversion, crushed, and groomed. At

the sites which were observed, no coal dust could be seen, except for small
amounts raised when coal was -moved from a vessel unloading area to storage.
It should be emphasized that this amount of dust was very small, and that the
characteristics of shipments and other conditions will vary from site to site.
However, if fugitive coal dust generation is minimized in unloading and
handling, then potential problems with turbidity in adjacent water will be

lessened in coastal areas.

Land based effects of coal transportation and unloading are
principally rail corridor conflicts and shoreline access competition with
other coastal users. Coal unloading facilities, along with the their
associated coal-using plants are usually located away from sites of other coal
facility activities to avoid conflicts. These unloading areas can require
large amounts of land, however they can be situated to reduce the length of
shoreline that they front on if sufficient area is available inland from
coastal areas. That is, rather than being aligned linearly along the coast,
unloading facilities and storage areas could be aligned perpendicular to the

shoreline.

Most of the communities along rail corridors originally benefited
from the presence of the railroads, yet the advent of longer and slower moving
unit trains has intensified some undersirable results for communities.

Measures can be taken, however, to reduce the effects of unit train transport
and these are covered in the mitigation strategy below.

OVERALL COMMODITIES AND GOODS MOVEMENT

Coal is only one of many commodities and goods transported on the
water, rail, and highway systems. The effects of coal transportation and
unloading are often difficult to separate from the effects of transporting
many other commodities and goods. Coal transportation does not dominate the
use of any transport mode, but coal may be predominant in commodity deliveries
to coastal coal-using facilities.

The effects of moving coal are not exclusive to coal. Other
commodities being transported generate dust, have a greater potential for

degrading water quality, and create land use problems. Generally, coal, in
comparison with other commodites, is a safe commodity to transport and unload.

CRITERIA FOR ASSESSING THE SIGNIFICANCE OF EFFECTS

Throughout this report environmental and socio-economic problems have
been addressed according to the activities contributing to them. However,
there is a need to establish priorities when dealing with the entire range of
effects on the environment. To do this, a systems approach may be preferable
because some effects may not be severe over the whole spectrum of coal-related

activities.

When looking at environmental and socio-economic effects, not all
criteria for setting priorities are given equal weight in evaluation.

Although the scope of this study is general and generic, most of the

impact criteria are determined on a regional basis. A high degree of
objectivity is always desired when ranking problems, but a certain amount of
subjectivity is involved because the study is regional and the information
gathered is problem-specific and quantification is inherently difficult. This
subjectivity can be reduced by doing a site-specific analysis.

The criteria for evaluating the effects of coal
unloading/transshipment facilities in the coastal zone are:

� emphasis in literature -- the most severe effects are frequently
cited and documented in the pertinent literature.

� personal communication with experts -- communication with
recognized experts helps determine the most important effects.
Experts include researchers, scientists, regulatory agency
representatives, etc.

� magnitude of effect -- the term "magnitude" is used to mean
degree, extensiveness or scale of effect. The analysis of
magnitude of effect, although in some ways subjective, can
nevertheless be factual and unbiased as long as it does not
include weights that show preference or bias. (Lepold et al,
1973) Other considerations include the range or the physical
area covered and the degree of importance to the environment.

� duration of effect refers to time frame of the effect on the
environment (e g. short term or long term). Of prime
importance here is the ability of the natural system to return
to its normal state- after being affected. Aside from short-term
and long-term effects, duration also refers to the
continuousness or intermittence of an impact. So, duration of
effect has to be looked at in relation to all of these causal
factors affecting the environent.

� public (social) cost of effect -- refers to the human
environemnt in relation to effects on the physical environemnt.
Major adverse changes in the human environment can be
interpreted as having a high social cost.

� coastal sensitivity -- attempts to separate coastal and
non-coastal activities and the associated effects on the
env ironment . Also, coastal sensitivity refers to the severity
of effect associated with coal movement and storage specific to
the coastal zone.

Based on these objective and subjective criteria, a summary of the
potential environmental effects follows.

SUMMARY OF POTENTIAL ENVIRONMENTAL EFFECTS

This summary of environmental effects is intended to give the
proposer and the reviewer an overview of the potential consequences that
should be considered in evaluating a proposal for a coal unloading facility.
No attempt is made here to indicate which effect is more important nor to
suggest that coal should not be transported and used. The significance of
effects will be dictated by the site-specific circumstances. The effects are
also relative: what may appear to be very significant might be minor in the
overall scheme of using coal or producing energy. Most experts concur that
from an environmental standpoint, coal is a safe commodity to transport,
unload and transship. A discussion of potential environmental effects of coal
transport and unloading follows.

Fugitive Coal Dust Generation. Of all the effects associated with
coal movement and storage in the coastal zone, fugitive dust generation will
probably be the most important, affecting air quality, water quality, and
terrestrial ecosystems.

Not much is known about the effects of coal dust in the atmosphere.

The small amount of information that is available has focused on the adverse

effects on human health, structures and materials, and economically important
plants . (Dvorak et al, 1978) Also, little is known about the effects of coal
dust on the natural ecosystem. Coal dust does have the potential to combine
and react with other atmospheric pollutants to form various secondary
pollutants, such as sulfate aerosols and peroxyacetyl nitrate (PAN). (Dvorak
et al, 1978) In addition, coal fines in the atmosphere have the potential to
sorb gaseous materials. These particles may then find their way into the lung
tissues of humans and animals by being inhaled (communication, W.C. Sonzogni).
The gases that are sorbed by coal often come from smelters and power plants,
facilities that use coal or are found near coal storage areas.

Coal fines in the atmosphere contain a relatively high percentage of
large size particles. Particles exceeding 25 n (microns) contain 50-85% of
the total mass. These large particles settle quickly, but coal particles 5 n
settle slowly and can be dispersed great distances by updrafts and turbulence.
It is the smaller particles which are most likely to end up in the lower
respiratory tract of humans and animals or to penetrate stomatal openings in
plants, causing leaf necrosis. (Dvorak et al, 1978) For a more complete
discussion of coal dust effects on the atmosphere see Technical Appendix G.

Waters may receive atmospheric coal dust through settling or from
precipitation. The major concerns associated with coal fines in the water
include increases in dissolved and suspended solids, and increases in trace
elements. (Missouri River Basin Commission, 1979)

Coal dust may fall or be blown into a waterway during loading and
unloading at a coal terminal. Turbidity is the parameter most likely to be
severely affected during these operations. Increased turbidity may adversely
affect aquatic ecosystems by decreasing phosynthetic activity in plants
because of reduced light penetration, as well as contributing to the
destruction and displacement of aquatic fauna by the depositing of a
smothering blanket of particulates. (Dvorak et al, 1978).

Release of Toxics from Sediments. Toxic release from sediments can
adversely affect water quality by altering the chemical equilibrium at the
sediment-water interface, causing elevated BOD (biochemical oxygen demand),
COD (chemical oxygen demand), and a reduction in DO (dissolved oxygen).
(Commerce Division, Long Beach Harbor, 1978)

This may result from increased loadings of coal fines to a harbor, as
well as from the resuspension of bottom sediments caused by dredging and
vessel passage. The severity will depend upon the harbor dynamics (e.g., flow
rate), the quality of the sediments, the hardness of the water, and several
other site specific factors. (Commerce Division, Long Beach Harbor, 1978)

Aquatic Ecosystem Disruptign. Changes in water quality can adversely
affect aquatic ecosystems. Turbidity associated with spillage of coal and
dredging can damage or kill aquatic organisms on the bottom of a harbor.
(@ommerce Division, Long Beach Harbor 1978) Potential pH changes associated
with coal dust in a waterway may reduce the suitability of an area for aquatic
vegetation, as well as for fish populations and spawning. (Dvorak et al 1978)
Dredging activities and vessel passages also may disrupt fish spawning
behavior. (Roy F. Weston Inc., 1974) For a more complete discussion of coal
related activities affecting aquatic ecosystems see Technical Appendix G.

Erosion. Before construction of unloading/transshipment and
stockpiling facilities, the area has to be graded, thereby stripping the
entire site of existing vegetation. Loss of soils from erosion occurs during
the removal, reapplication, and stockpiling phases of coal handling (Missouri
River Basin Commission, 1979) Wind erosion may also be a problem on exposed
soils, causing fugitive dust generation. This dust then falls on plant leaves
decreasing transpiration and photosynthesis. (Szabi, 1978)

Erosion will also occur on shorelines, especially along rivers,
conneting channels, and harbors, because of changing water levels, moving ice,
and waves caused by vessel passage in connecting and contricted channels.
(Valentine-Thomas & Associates, 1979) Although the amount of shore erosion
occurring in a channel that can be attributed to vessel movement (and

specifically to coal vessels) cannot be discerned in certain areas, it may be
quite significant.

Associated with shoreline erosion is the problem of increased
turbidity. Increased turbidity (as mentioned earlier) will contribute to the
many associated problems of sediment loads as they affect the flora and fauna.

Noise. Noise is a potentially dangerous by-product of every aspect
of coal transportation and storage in the coastal zone. The general effects
that these noise levels will have on humans and other animals are unknown, but
depend on several site-specific factors such as location and duration of
impact. Physical environmental explanations of noise problems (i.e., adverse
effects on heart rate, blood pressure, etc.), generally involve considerations
of overstimulation. (Porteous, 1977) Much of the noise associated with coal
unloading/ transshipment is intense and of long duration, and may be confined
to the site. For a more complete description of noise impacts see Technical
Appendix G.

Land Resource Requirements. Land will be required for coal unloading
and transshipment facility expansion along the Michigan coast. In most cases,
this land is only a portion of the total land needed to complete the coal use
process; i.e,, a coal unloading facility is usually associated with a power
plant or other coal-burning structure. The value of the coastal land for
other purposes should be considered. Configuration of the coal unloading,
handling and using structures must be considered in relation to efficiency of
industrial processes and in relation to other coastal uses.

EVALUATION STRATEGY

The evaluation strategy covers the following activities related to
coal unloading:

Part 1. Transportation
a. Water Transportation
b. Rail and Truck Transportation

Part 2. Facility Development and Operations
a. Dredging Activities
b. Dredge Material Disposal

c. Nearshore Construction

d. Facility Development for Land Delivery
e. Operations for On-site Handling of Coal

For each activity the following information is provided:

1. Activity Description

2. Potential Effects

3. Existing Policy Framework

4. Evaluation Guidelines
5. Potential Mitigation Measures
6. Policy Recommendations

This evaluation strategy was developed with the project reviewer in
mind. A proposal can be traced completely through the evaluation process from
transportation to coal storage, or beginning at an intermediate point. In
order to make it convenient for the project reviewer and to make sure no
potential effect, policy or mitigation measure is left out, the strategy has
some intentional redundancy in its organization.

The effects of each activity, listed under "Potential Effects," will
vary from site to site. Since this report is the result of a generic and not
a site-specific examination of effects, the reviewer will have to use policies
and procedures set down in the laws, rules, and regulations cited to evaluate
site-specific proposals for coal unloading and transshipment facilities.

A Note on Potential Mitigation Measures

The potential mitigation measures described below reflect a
comprehensive but not exhaustive list of efforts that can be taken to reduce
the particular problem. Many of the measures are already used to reduce
impacts from coal delivery and facility development. Some are exclusive while
others are complementary. Not all will be cost-effective at every site.

These circumstances will need to be evaluated individually for each site.
Appendix H gives a more detailed description of mitigation measures.

Since little cost information of use in a generic study like this was
available for mitigation measures, the relative cost effectiveness of each
measure could not be determined. The economics of each site along with other
social and environmental considerations should determine the correct approach
to take if the problem exists or is critical enough to require a remedy.

Furthermore, the consistency requirements of the coastal zone
management program require that the activities of other state and federal
agencies be consistent with the state's coastal management program. This
consistency requirement can be used as a tool for assisting in the mitigation
of any potential problems arising from coal transshipment facilities or
expansions by incorporating this evaluation strategy in the review of proposed
facilities or changes.

Part I

TRANSPORTATION

WATER TRANSPORTATION

Activity Description

Water transportation of coal is defined simply as the operation of
ships which carry coal. Supplementary evaluation guidelines for constructing
vessel coal unloading facilities and for dredging, activities to enable vessel
transport, are outlined in Section 2, Guidelines for Facility Development.

Potential Effects

Environmental impacts of waterborne coal transport are primarily of
two types: movement impacts and discharge impacts. Movement impacts include
land damage such as shore erosion, problems resulting from the resuspension of
particulates, and structural damage to onshore facilities. The
characteristics of ship operation which most directly determine these impacts
are vessel speed and proximity of operation to the shoreline and channel
bottom.

Discharge impacts refer to problems associated with bilge discharges,
sanitary waste disposal, and ballasting; bilge discharge would probably be
most important . Coal dust may find its way into the bilges of ships and
could, if expelled, have an uncertain effect on the marine environment.
Ballasting and sanitary waste discharge impact are believed to be not
significant with respect to coal. Coal vessels do not store their cargo in
ballast compartments, so coal dust would not be expelled with ballast
discharge.

'10

The Belle River American Steamship's 1000 foot, 79,000 ton capacity self unloader serving Detroit Edison.
(Photograph courtesy of the Detroit Edison Company)

Existing Policy Framework

Movement Effects Policy

Federal

Ports and Waterways Safety Act of 1972 P.L. 92-340

Attempts to prevent damage to structures in , on, or
immediately adjacent to the navigable waters of the United
States or the resources within these waters.

With respect to the structural damage which may be caused by vessel
operation within the coastal zone, the Ports and Waterways Safety Act gives
the Secretary of Transportation the power to:

(1) prevent damage to, or the destruction of, any bridge or
other structure on or in the navigable waters of the
United States, or any land structure or shore immediately
adjacent to such waters; and

(2) protect the navigable waters and the resources therein
from harm resulting from vessel or structure damage,
destruction, or loss.

Action taken pursuant to the prevention of such damage may include but is not
limited to such measures as establishing water or waterfront safety zones or
the enactment of other measures for limited or controlled access or activity
when necessary for the protection of any vessel, structure, waters, or shore
area. (33 USC Subsection 1225[al).

Regulations promulgated by the Secretary of Transportation
implementing the Ports and Waterways Safety Act are authorized under Section
1231 and may be found in Title 33 of the Code of Federal Regulations (CFR).
(33 USC Subsection 1231[al).

geographical points and within individual harbors have been established
pursuant to the act for many Michigan ports and waterways. These include:
The St. Marys River (Part 92.49); Keweenaw Waterway (Part 162.115); St. Clair
River (Part 162.135); Detroit River (Part 162.135); Rouge River and Short Cut
Canal (Part 162.140); and various harbors on Lake Michigan (Part 162.120).

In addition to these limitations, part 164.15 of Title 33 contains
general safety rules concerning the responsibility of vessel owners or masters
while underway. Included in their responsibilities are consideration for the
proximity of the vessel to fixed shore and marine structures, the comparative
proportions of the vessel and the channel, the density of traffic, the damage
that might be caused by the vessel's wake, and any local speed limits. All of
these are variables of shoreline erosion, particulate resuspension and
on-shore structural impacts.

Authority for enforcing the rules set forth in Title 33 can be found
in Part 160. Part 160 states that the law enforcement responsibilities under
the Ports and Waterways Act are held by the United States Coast Guard District
Commander, "Captain of the Port", or an authorized representative of one of
these. Violation of a regulation issued under the act carries a civil penalty
of not more than $10,000.

Discharge Effects Policy

Federal

Federal Water Pollution Control Act Amendments of 1972, P.L.
92-500

Section 311--dealing with oil and hazardous substance
liability--regulates the discharge of vessel bilge water
containing such substances and may indirectly control the
discharge of oily liquids containing coal fines.

Impacts other than those caused by the movement of vessels through
the water would most likely constitute discharge impacts and would be related
to water quality protection laws and regulations. The expulsion of coal dust
containing liquids from vessels operating in the Great Lakes and connecting
channels would have an uncertain impact on the environment, and clearly should

be examined Such discharge would probably occur, if at all, as a result of
fugitive dust finding its way into a vessel's bilge, which often serves as a
kind of "catch-all" for uncontrolled vessel wastes and seepage.

The discharge of polluting substances into the water of the United
States is addressed under provisions within the Federal Water Pollution
Control Act (86 Stat. 816,868). The expulsion of such substances by vessels
falls under the jurisdiction of the Secretary of Transportation and the United
States Coast Guard, and is addressed by Title 33 of the CFR. The discharge of
liquid containing coal dust is not specifically addressed in these
regulations, as it is not perceived to be a major problem. However, to the
extent that coal dust mixes with other bilge that is regulated, it may be
indirectly covered.

Parts 155.220, 155,340, 155.350, and 155.360 of the CFR require that
vessels may not operate without a system for the retention and controlled
disposal of "oily bilge slops." The discharge of noxious bilge is a violation

under the Water Pollution Control Act.

Potential Mitigation Measures

Movement Effects

� Establishing and enforcing speed limits can assist in reducing shore
erosion, resuspension problems, and risk to structures resulting from
waves and/or collisions.

� Modification of channels is often used as a technique to reduce ship
induced shoreline losses. Channel modification may be economically
justifiable for reducing movement effects, but it may also aggrevate ship
movement impacts depending on local conditions and the nature of the
project .

� The selective use of dredged material might help to dissipate some of the
energy of passing vessels, via small subsurface features. Also, selective
placement of dredged material may limit near shore sediment transport and

some of the water movement, and reduce the amount of sediment released
into the channel.

Shoreline Protection -- Shoreline protection methods that have been used

to alleviate ship-induced effects include:

(a) Gabion Shoreline Protection -- Gabions are wire baskers filled with

rocks and wired together to form a wall or a lining. Gabions are
0
economical, stable on steep slopes, and have low maintenance
requirements and long life in the absence of destructive forces.

There are some disadvantages to gabions: their tear resistance may
not be high enough to withstand heavy ice movement during the spring
ice break-up, and they may be expensive to install, because
contractors maybe unfamiliar with large-scale installations.

(b) Rip-Rap Shoreline Protection -- The realignment of Shoreline by
selective filling and armament with stone or concrete. Where proper
shoreline conditions exist, rip-rap is an economical way of checking
shoreline erosion. It also provides good wave energy dissipation.

(c) Sheet Pile Shore Protection -- Anchored bulkheads, of flexible steel
sheet piles restrained by tiebacks, are often used to protect a
shoreline. They have a long expected life, have small maintenance
requirements, are aesthetically consistent, and provide recreational
access for fishing and boating.

The major drawback of anchored bulkheads is the high cost for

materials and installation.

(d) Vegetation -- Establishing vegative plantings is often the most
inexpensive, effective and environmentally sound technique for
shoreline protection. The major drawback can be the difficulty of
establishing and retaining vegetative cover.

Discharge Impacts

0 Pumping noxious bilge waste into onshore recepticles, as already required
by law, will eliminate discharge impacts.

0 Separating noxious from nonnoxious bilge waste prior to pumping of bilge,
as already required by law, will reduce overboard discharge effects.

Evaluation Guidelines

1. Movement Effects

A. General

(1) Can existing channels and berths accomodate increased coal vessel
delivery? If not, then the modification of the submerged lands
and/or shore facilities needs to be considered.

(2) Is use of the channels and harbors for coal transport in this area
consistent with the coastal management plan?

B. Shore Erosion

(1) Is the proposed area a high risk erosion area under the authority of
the Shorelands Protection and Management Act?

(2) Is the area a shoreland area of particular concern under the coastal
management plan?

(3) Has shore erosion occurred in the vicinity of the proposed facility?

(4) Has an analysis of potential shore erosion been done for the channel
and/or harbor?

(5) Will an increase in use of the channels and harbors cause an increase
in shore erosion? If not go to c. below.

(6) Does the analysis indicate the type of erodible material and expected

shore recession?

(7) Does this analysis indicate major or minor shore erosion?

(8) Have mitigation options been evaluated? Do these options include

those outlined above?

(9) can the proposed mitigation be practically and economically done?

(10) Has the interaction between the mitigation proposed and the shore
erosion process been determined?

C. Resuspension of sediment

(1) Is resuspension of sediment likely to occur from increased coal
movement?

(2) Is the sediment polluted? What is the nature of the pollutants?

(3) If the channel or harbor must be redeveloped to accomodate increased
coal movement, will resuspension likely occur?

(4) Do any sensitive aquatic habitats exist in the area (especially, fish
spawning areas)? Will resuspended sediments affect these habitats?

(5) The significance of resuspension must be evaluated on a site specific
basis.

D. Structural damage

(1) Has structural damage from vessel passage previously occurred in this
area?

(2) Is structural damage likely with increased coal movement? Will this
structural damage be significant?

2. Discharge Effects

Coal transportation is not anticipated to increase the hazard of bilge
discharge. The effects of bilge discharge are already covered by existing
law. These cannot be evaluated unless a vessel operator violates this law and
the Coast Guard or other,agency does the appropriate monitoring.

Policy Recommendations

1. Programs and regulations should be developed and enforced to increase the
cooperation between the Michigan Department of Natural Resources and the
United States Coast Guard to minimize onshore vessel impacts.

Variable factors, such as vessel speed and route, may substantially reduce
shore erosion and suspension of particulates. Coordination between
agencies capable of identifying the sources of these problems and agencies
such as the USCG, possessing enforcement authority under the Ports and
Waterways Safety Act, could reduce of shore erosion where it is affected
by passage of a potentially larger number of coal vessels.

2. Emissions from coal-fired transport vessels should be investigated to
determine whether regulations should be developed under the of the Clean

Air Act.

Contacts with experts in the transportation field of transportation have
indicated that the use of coal to power lake vessels may be significant in
coming years . Emissions from this source are not currently regulated
under the provisions of the Clean Air Act.

RAIL AND TRUCK TRANSPORTATION

NOISE

Activity Description

Diesel locomotives are responsible for most of the noise associated
with rail transport. Contributing components are the horn, the diesel exhaust
muffler, the diesel engine and surrounding casing, the cooling fans, and the
wheel/rail interaction. Additional noise comes from empty cars with loose
chains and vibrating parts.

Electric locomotives also generate noise. The horn, cooling blowers,
wheel/rail interaction, and the electric traction motors all make noise.
Braking the locomotive from high speeds produces the most noise, but excepting
high speed braking, the electric locomotive is considerably quieter than the

diesel.

The major sources of truck noise are the engine, exhaust, cooling
fans, and tires. The high-compression diesel truck engine causes more
vibration and thus produces more noise than does the spark ignited gasoline
engine. Techniques for reducing noise from these sources are under study.

Potential Effects

Coal and other commodity transport is already generating noise in
many coastal locations. The effects of noise on the environment can range
from relatively mild problems such as occasional sleep disturbance at low
levels, to severe medical and emotional effects at extremely high levels.
Members of both human and wildlife communities may suffer such things as
increased stress levels, central nervous system damage (in extreme cases), and
disruption of normal behavior patterns. Increased noise in the coastal zone,
as a result of greater coal movement, could therefore produce detremental
effects in certain areas. The relationship between the of noise produced by
coal unloading and transshipment and surrounding land uses should be
evaluated. Most noise will be confined to the transportation corridors and of

short to medium duration.

"Ob,

Trucks are often used to transport coal over short distances, both on and off plant sites. (Photograph
courtesy of the Detroit Edison Company.)

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now*

'Oft W@-111-
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6966

oil

A full unit train often containing 90 cars or more awaits unloading. (Photograph coutesy of the
Detroit Edison Company)

In terms of frequency of impact, it is difficult to separate the
noise from rail or truck coal transport from the transport noise of other
goods and commodities. Along certain rail lines which carry a high proportion
of coal increased coal movement may have noticeable effects on noise levels.
A more definite or quantitive statement cannot be made unless specific
transport routes are evaluated in detail. However, the consequences for human
and other populations must be placed in the perspective of total commodity
transport. The incremental effects of increased coal movement in Michigan are
expected to be minimal. Specific sites may be more heavily affected.

Existing Policy Framework

Federal

0 Noise Control Act of 1972 P.L. 92-574

To protect health and welfare, ambient noise levels are
recommended; they may become standards for facilities
regulated by State and local governments.
State

0 Vehicle Noise Control Act P.L. 300 of 1949 as amended by Acts
73 and 492 of 1978 (Part of Michigan Vehicle Code)

Enacts state noise standards identical to federal
regulations, thereby broadening noise control coverage.

Section 4916 [a][11 of the Noise Control Act of 1972 mandates that
the Administrator of the Environmental Protection Agency, after consultation
with the Secretary of Transportation, shall publish regulations and standards
for surface carriers engaged in interstate commerce by railroad. These
regulations are to reflect the degree of noise reduction achievable through
the application of the best available technology, while taking into account
the cost of compliance. Consequently, the Secretary of Transportation, after
consultation with the Administrator of the EPA, is to evolve regulations to
insure compliance with the forementioned standards through the use of his
powers of enforcement and inspection under other Federal Acts (42 USC
Subsection 4916 [b]).

All rail noise standards are in force when the dB(A) level, or
A-weighted sound level in decibals) is measured in accordance with the
technical requirements of Subpart C of Part 201. It should also be noted that
these regulations set standards for locomotives and railcars manufactured
after December 31, 1976, only, and are not retroactive. Older cars and
locomotives would seemingly be exempt. There are no regulations specific to
unit train transport of coal. This activity would be covered under the
provisions of law generally.

Section 4917 [a] of the act deals with the creation of standards
dealing with noise emissions from motor vehicles in much the same way as
Subsection 4916[a] deals with railroad noise emissions. The regulations
enacted pursuant to this section can be found in Title 40 CFR Part 202, and
took effect on October 15, 1975. These provisions apply only to motor
vehicles engaged in interstate commerce, do not apply to auxiliary equipment
normally operated when the vehicle is stationary or moving at less than five
miles per hour, apply only to motor vehicles which have a gross vehicle weight
rating or gross combination weight rating of more than 10,000 pounds, and do
not apply to warning devices such as horns or sirens. The specific
regulations are found in Subpart Bof Part 202.

Sections 4917[c)[11 and [2] of the Federal Noise Control Act of 1972
specify that no state or political subdivision of a state may adopt or enforce
standards applicable to the operation of motor carriers engaged in interstate
commerce unless they are identical to the standards proposed by the Federal
regulations and the United States Secretary of Transportation has been
consulted. The State of Michigan has enacted regulations, under Act 300 of
the Public Acts of 1949, as amended by Act 73 and 492, Public Acts of 1978,
which are identical to the federal standards for motor carriers and has
thereby broadened the noise control coverage within Michigan to include state
highways and streets, regardless of the presence of an interstate activity.
The Michigan act also broadens the applicability of the standards to include
all motor carriers with a gross vehicle weight rating or gross combination
weight rating of more than 8,500 pounds as opposed to the federally determined
10,000 pound level. (Act 300, PA 1949, as amended by Act 73 and Act 492, PA
1978, Sec. 707c. [11[a][i][ii][iiij).

Potential Mitigation Measures

For both trucks and rail, emphasis should be placed on reducing noise
at the source rather than on the use of shields or covers as secondary noise -
reduction devices. However, engine covers and panels have proved to be the
most successful short-term approach to reducing noise.

� For truck and trains, modified casing with acoustical absorbent material
around the engines can lower overall engine noise.

� Rail mufflers on the exhaust system can greatly reduce the noise from

diesel locomotives.

� The use of a continuous welded rail can achieve noise reductions greater
than 5 decibels. It may be possible to use this type of rail in urban
areas. Otherwise, proper maintenance of the rail and bed will keep noise
from this source sufficiently low.

For trucks, mufflers have been effective in reducing noise and research on
new types of mufflers is being conducted in an effort to reduce noise even
further. Possible innovations include placing a resonator close to the
exhaust manifold, exhaust pipe wraps, and double wall or laminated exhaust
pipes.

� Railyards and lines may use a buffer zone of natural vegetation or
sound-absorbing structures to reduce noise impact on cormnunities.

� To the extent feasible, the impact of rail and truck movement may be
reduced by acquiring scheduling commitments or by permitting delivery only
during specified hours.

Evaluation Guidelines

1. What are the ambient noise levels along the transport route?

2. How many trips by rail or truck are projected to handle the increased

movement of coal?

3. What areas are potentially affected by noise -- residential, commercial,
industrial, recreational, public and semi-public -- along the transport

route?

4. Are there any areas along the route which could be expected to be
sensitive to increased noise levels? What periods of the day would be
particularly affected? What is the expected duration of the forecasted
noise levels?

5. Will the increase in noise from coal movement significantly affect land
uses adjacent to the transport route? If not, mitigation measures may not
be necessary. Site specific circumstances will be important.

6. What mitigation techniques will be considered?

a. Alternate technology

b. Scheduling

C. Buffer areas

d. Alternative routing

Policy Recommendations

1. The State and the U.S. Environmental Protection Agency (EPA) should work
towards the updating of regulations concerning allowable coal carrier

noise emissions.

As new technology has been developed in recent years with respect to noise
emissions, tighter regulations in the form of lower allowable decibel
limits may now be achieved. These regulations should probably only apply
to new vehicles to prevent economic hardships for current operators and
must be promulgated by the EPA due to the preemptory nature of the Noise

Control Act of 1972.

2. The State and U.S. Environmental Protection Agency should work towards
completion of railyard noise standards which would include standards for
truck and train loading and unloading.

The loading and unloading of coal to and from trucks and trains has the
potential for producing significant noise levels. To adequately regulate
rail yard noise production as a whole, these sources of noise should be
included in any standards promulgated.

FUGITIVE DUST

4ctivity Description

Fugitive dust is produced during the loading, unloading, and
transportation of coal and may potentially effect the coastal zone environment
in many ways. During loading and unloading, dust may be generated by
collisions between pieces of coal and/or coal hitting dock surfaces
or ship structures following a free fall from equipment such as conveyors.
During transportation, wind blowing over uncovered coal in trucks
or rail cars may raise dust.

Potential Effects

Effects on vegetation, water, air, and man-made structures are
possible by-products of fugitive dust generation. These effects may be
significant in the coastal zone due to factors such as the proximity of
dust generating sources to the waters, wind pattern and velocity differences,
and higher ground water levels. Fugitive dust can cause difficulties with
transpiration through plant stomata, aesthetic problems, and other
undersirable chemical and biological changes.

Existing Policy Framework

Federal

0 Clean Air Act as amended P.L. 91-604 as amended by P.L.
92-157, P.L. 93-15, P.L. 93-319, P.L. 95-95

Directives issued under Title I of the act have mandated
fugitive dust mitigation provisions in State Implementation
Plans (SIP's) for some areas.

State

0 Regulations proposed for adoption t o Michigan State
Implementation Plan proposed R. 336.1370 - R. 1372

Proposed fugitive dust control programs for Michigan sources.

Federal policy toward air quality is implemented under the Clean Air
Act Amendments of 1977. In this act, Congress directed the United States
Environmental Protection Agency to establish primary and secondary National
Ambient Air Quality Standards [NAAQSI to protect the public health and
welfare, and directed the states to develop and adopt State Implementation
Plans [SIP's] to attain and maintain these standards. Part D of Title I of
the act outlines the necessary provisions of a satisfactory SIP for a

non-attainment area.

The Environmental Protection Agency issued an August 1977 memorandum
concerning Guidance on SIP Development and New Source Review in Areas Impacted
by Fugitive Dust. This Guidance recognizes fugitive dust as a significant
contributor to the paticulate matter problem within urbanized areas throughout
the nation and distinguishes between its impact on rural versus urban areas.

The State of Michigan Air Quality Implementation Plan Revisions of
1979 contained provisions under Commitment for Fugitive Dust Regulations, in
which the state committed itself to developing fugitive dust regulations for
at least the primary nonattainment area in Wayne County and possibly a wider
geographic area. Rules have since been promulgated for the entire state of
Michigan representing fugitive dust additions to the state implementation
plan, and are currently being reviewed. The Department of Natural Resources
is committed to January 1, 1981, for adoption of these rules into the Michigan
SIP. In addition to the statewide rules, Wayne County is evolving its own
requirements.

Included in the rules currently under review are several sections
which would relate directly to fugitive dust created in the transportation of
coal (see Appendix). These provisions may be cited as Proposed Rules
R.336.1370-R.1372 of the Michigan Administrative Code. Most important within
these rules are R. 336.1371, Fugitive Dust Control Programs, which describes

the requirement for fugitive dust control programs for applicable facility
operators including coal transporters and R. 336.1372, Fugitive Dust Control
Program; Required Activities; Typical Methods, which outlines necessary
program content and typical control methods.

Potential Mitigation Measures

0 Better designed trucks with covered bodies are the most effective means of
reducing wing loss and spillage. Spillage and dust will remain a problem
with older, uncovered trucks. One solution would be to use tarpaulin

covers.

0 To control wind loss of coal dust, wind guards (30 cm high) are partially
effective for uncovered trucks or rail cars.

0 Sealing the surface of each load of coal with a latex-polymer or an
asphalt emulsion has been effective in reducing wind loss.

0 Coal should be wet down before transport. Washed coal retains much of its
moisture, which aids in reducing wind losses.

0 Dustproofing the coal with oil or calcium chloride is a common practice.
Application of dust suppressants is most efficient while the coal is in
the air, as during loading.

Evaluation Guidelines

1. What are the ambient particulate levels along the transport route?

2. How many trips by rail or truck are projected to handle the increased

movement of coal?

3. Can specific factors be identified which could increase dust generation--
wind, source of coal, rough track?

4. Will any communities or environments along the transport route be

sensitive to coal dust?

5. If fugitive dust becomes a problem, can appropriate techniques be applied
or retrofitted to reduce this effect?

6. Will the increase in particulate levels from coal movement significantly
affect adjacent use of the transport route? If not, mitigation measures
may not be necessary. Site specific circumstances will be important.

7. What mitigation techniques will be considered for the potential effects?

a. Alternative technology

b. Buffer areas
c. Alternative routing

Policy Recommendation

Rules and regulations concerning fugitive dust mitigation techniques
during rail transport should be promulgated and enforced.

Because substantial amounts of fugitive dust are produced by rail
transport of coal, regulations such as those proposed for truck transport as
amendments to the Michigan State Implementation Plan should be enacted. As
rail transport is often an interstate activity, federal regulations in this
area may be most effective.

COMMUNITY EFFECTS FROM RAIL TRANSPORT

Activity Description

Unit train rail transportation of coal may cause disruptions within
communities through which the coal is moved.

Potential Effects

Coal unit trains can interfere with the activities of communities
through which they pass since they are generally longer and slower moving than

other types of rail transport . Coal train movement could divide a community
which might hamper emergency services or endanger and inconvenience motorists
and pedestrians, and affect community safety.

Existing Policy Framework

State

0 P.A. 198 of 1873 as amended by P.A. 239 of 1966

Deals with regulation of the allowable duration of rail
crossing blockage.

The State of Michigan Compiled Laws contain provisions which limit
the obstruction of vehicular traffic by a railroad train to five minutes (see
above citation or 1970 Michigan Compiled Laws Annotated 466.23). These
provisions also make it unlawful for successive train movements to obstruct
any vehicular traffic on any public streets or highways until all previously
delayed traffic has been cleared, or a period of five minutes has elapsed
between train movements, and impose penalties for violation of these laws
(Secs. 466.24 and 466.25).

It should be noted that although these laws appear to cover the
problem of vehicle disruption quite thoroughly, the average time for which a
unit train blocks a crossing ranges between 1.5 and 3.4 minutes (Ernst &
Whinney, 1979), and crossings of such a duration are not rgulated under the
above cited laws. To efficiently assess and regulate the impact of unit train
movement through a community, one must consider factors such a total traffic
delay times, which often are more substantial than the actual times of
crossing, and do not seem to be currently regulated in Michigan.

Potential Mitigation Measures

0 Communities anticipating increased rail shipment of coal should evaluate
the existing rail infrastructure and provide adequate warning equipment at
crossings. Switching operations. should be updated to eliminate
unnecessary delays at crossings that have no trains approaching.

� To the extent feasible, the community should acquire scheduling
commitments with the railroads to establish a predictable or consistent

train schedule

� Railyards and transshipment facilities should incorporate a buffer zone
using natural vegetation to reduce adverse aesthetic effects, where

feasible .

� Alternative emergency routes should be planned for communities interrupted
by frequent train transportation. The affected community should look into
the possibility of using the emergency services of neighboring communities
when delays at crossings threaten emergency service.

� When feasible, new rail lines or spur lines should be routed through the
outskirts of the community to avoid community disruption.

Evaluation Guidelines

1. What rail interference on communities is currently being experienced?

2. To what extent will rail movements through communities be increased with
completion of the proposed facility?

3. Of the communities affected by increased rail delivery of coal, what are
the major characteristics of. community structure and what will the major
community interferences likely be?

4. Are there economically feasible alternative rail routes avai.lab le for coal
delivery with potential for fewer community impacts? Are these routes
considered in the proposal?

5. Is scheduling information available suggesting when movement of coal
through communities will likely occur?

6. Have design studies been undertaken for structural or non-structural
measures to minimize any of the identified current or anticipated
community impacts?

Policy Recommendation

Low cost solutions to rail interference with community activities do
exist and should be examined by state and regional planning agencies. These
could include both structural and non-structural projects such as modification
of operating practices, rail road facilities, community transportation
facilities, or community development patterns.

The Coastal Energy Impact program should consider grants for planning
and ameliorating the effects on communities through funds for grade
separation/ overpasses, pedestrian walkways, signals and other safety measures,
as well as non-structural plans for adjacent land patterns.

ROAD DAMAGES FROM TRUCK TRANSPORT

Activity Description

Trucks transporting heavy commodities such as coal may increase
damage to road surfaces in some areas.

Potential Effects

Increasing transportation of coal by truck may require redesign of
local roads and will increase maintenance costs for pavement cracking,
potholes, and damage to access ramps and shoulders. The volume of coal moved
by truck into and within Michigan is small, but the effects may be locally
significant. The major continual movement of this type occurs in the Traverse
City area between the utility coal unloading facility and the powerplant.

Existing Policy Framework

State

0 Michigan Vehicle Code P.A. 300 of 1949 as amended by House
Bill 5675 of 1980 (act number assignment pending)

Regulations evolved pursuant to. this act related to truck
weight restrictions

The State of Michigan does have Maximum Truck Loadings and Dimensions
(Michigan Department of Transportation, Numbered T-1 1/79), regulations
pertaining to the operation of trucks and trailers according to Act 300, P.A.
1949 as amended. Truck dimensions in Michigan are not restricted strictly by
weight, but rather by number of axles and vehicle configuration. Special
permits are issued by the Department of Transportation for the occasional
movement of oversize or overweight vehicles or loads which cannot be
dismantled, reduced, or otherwise rearranged to come within the legal limits.

The upper limit under Michigan law for any one axle is 18,000 lbs,
with a maximum allowable axle limit of eleven. Vehicle configurations and
axle spacings are also regulated. Michigan's truck weight restrictions are
generally considered to be quite lenient relative to regulations in other
states. Highways within Michigan are, however, designed to withstand the
18,000 lb/axle load over a twenty-year life span.

Potential Mitigation Measures

� Prohibit operations of coal trucks on roads not designed for their use.

� Assess a tonnage tax for use of roads.

Evaluation Guidelines

1. How many truck deliveries are anticipated for fulfilling the facility
needs? What weights (size of load) is anticipated? Over what distances
will the truck transport be accomplished?

2. What is the condition of the roads which will be used for truck transport?
Can the road accomodate the increased coal movement within acceptable

limits of road wear?

3. Should special weight or other transportation restrictions be enforced
during periods of the year when damage to roads is more likely to occur?

Policy Recommendations

Cooperation between state transportation agencies should be pursued
concerning weight limitations or regulations on interstate coal transport by

motor carrier.

Part 2

FACILITY DEVELOPMENT AND OPERATIONS

DREDGING ACTIVITIES

Activity Description

Dredging refers to of removing sedimentary materials from lakes,
harbors, and connecting channels to maintain, improve, or extend navigable
waterways. Dredging involves the interrelated actions of excavation,
transportation, and disposal of material (dredge material will be dealt with
separately) . Barges usually draw twelve feet or less of water and deep draft
Great Lakes vessels currently utilize about 26 feet. These drafts usually
dictate depth and amount of dredging.

Potential Effects

During the excavation phase of a dredging operation the more commonly
experienced short-term effects include:

- creation of turbidity and reduction of light penetration in water
- resuspension of sediments in the water column
- disturbance and destruction of aquatic organisms and habitat
- dissolved oxygen depletion
- creation of floating scum and debris
- disruption of recreational activities

Increased turbidity contributes temporarily to diminished overall
biological productivity in river, harbor, and lake environments, and it causes
reduction of light penetration which decreases photosyntheti.c activity.

Resuspension of sediments during excavation contributes to the
release of nutrients and other contaminants entrapped in the sediments, the
disturbance and destruction of fish and benthos and their habitats, depletion
of dissolved oxygen in the water table, and the creation of floating scum and

debris Minor disruption of recreational activities in the harbor could also
occur . The movement of dredges and barges to the disposal site adds to the

traffic in the harbor and creats obstacles to the movement of recreational

water craft.

Long-term effects of the excavation phase of dredging include:
(1) increased shore erosion due to changes in current patterns and bottom
geometry (bedform) which result in destabilization of the coastline, and (2)
decrease in recreational activities including fishing and swimming because of
changes in fish populations and species composition, and a decrease in water
quality.

Environmental concerns in the material transportation phase of
dredging are related to operating techniques and equipment maintenance.
Spillage will be the main problem associated with the transportation of
dredged material, causing turbidity and disturbing the habitat of aquatic
organisms. The maintenance of equipment has a bearing on the losses occurring
during transportation either by barge, hopper vessel, or pipeline.

Material loss will be expected in cases where there are loose fitting
couplings at the bottom of bucket dredges, hopper dredges, and bottom dump
scows, and breaks in transport pipelines.

Existing Policy Framework

Federal

� Rivers and Harbors Act of 1899 as amended 33 U.S.C. 401-413

Permits are required for dredge, and fill activities in
navigable waters, which may affect facilities siting.

� National Environmental Policy Act of 1969 (NEPA) P.L. 91-190

Environmental Impact Statements (EIS's) must be prepared for
all major Federal actions significantly affecting the quality
of the human environment. Environmental impact Assessments
(EIA's) usually done to determine which actions require
EIS's.

State

0 Great Lakes Submerged Lands Act P.A. 247 of 1955

Regulates, by permit, the use, filling, or sale of submerged
lands within state boundaries.

0 Inland Lakes and Streams Act P.A. 346 of 1972

Regulates, by permit, activities including the dredging or
filling of bottomland, placement of structures, construction
of artificial waterways, and structural interference with the
natural flow of an inland lake or stream.

0 Geomaere-Anderson Wetland Protection Act P.A. 203 of 1979

Regulates, by permit, alterations of wetlands, including
drainage of surface water, construction, dredging and
filling.

0 Shorelands Protection and Management Act P.A. 245 of 1970

Regulates land uses and developments within (1) environmental
areas (2) areas prone to high risk erosion (3) areas within
the 100-year flood plain.

0 Michigan Environmental Protection Act of 1970 P.A. 127 of
1970

Provides litigation guidelines for cases involving the states
air, water, and other natural resources; and mandates the
consideration of environmental factors in administrative
decision-making.

Potential Mitigation Measures

0 Schedule dredging operations to avoid environmental impacts during periods
which appear to be susceptible to stress (i.e. fish spawning seasons).

0 Scheduling dredging operations to avoid recreational conflicts. For
instance, dredge in the fall when recreational boating has subsided below

summer levels.

Q Simple equipment maintenance and efficient operation can improve sediment
removal efficiency and reduce turbidity in surrounding waters.

0 Develop guidelines for use of floating turbidity curtains (diapers) to
help reduce turbidity. Turbidity curtains are effective in still water,

but will be ineffective.in areas where currents exceed 1 knot.

0 Use of a different type of dredge, (mechanical or suction-mechanical) can
at times reduce overall turbidity.

0 Specific on-site evaluations should be made on a case-by-case basis,
taking into consideration all of the environmental impacts (physical,
chemical, and biological).

0 Bucket dredges, hopper dredged, bottom-dump scows, and pipelines should be

well maintained to reduce material losses.

0 operating practices and maintenance standards should be established to
ameliorate potential impacts.

Evaluation Guidelines

1. Is the dredging proposal for maintenance or for initiating new

developments?

2. What proportion of total traffic moving through the proposed dredging area
is coal traffic? Are the vessels used for coal transport making the
principal demand for the dredging? If not, this is probably a multi-
purpose dredging project.

3. To what extent will the dredging alter existing shoreline configuration,
water quality, and resource and biological capabilities?

4. Does the dredging proposal fit into any existing regional economic or
environmental planning and development scheme?

5. Is the dredging proposal consistent with state and federal policies?

6. Have appropriate mitigation measures been considered?

Policy Recommendations

1. The state Departments of Natural Resources and Transportation should
prepare a coordinated, flexible, long-range dredging and dredge disposal
plan for coal and other goods and commodities transport. The plan should
include port needs, water quality, fish and wildlife habitat, public
health considerations and project alternatives.

2. Proposals for channel improvements such as dredging should examine
technological alternatives, such as using integrated tug barges.

Such alternatives, where feasible, would utilize transport modes less
dependent on deep channels and would decrease the need for both initial
and maintenance dredging projects.

DREDGE MATERILL DISPOSAL

Activi@ty Description

Dredge material disposal refers to redepositing aquatic bottom
sediments at another site. The disposal operations which represent the
greatest potential hazard to the environment. More information about dredge
material disposal is needed because (a) no single disposal alternative is
suitable for all regions or groups of projects, and (b) no single alternative
results in impacts so great that it can be dismissed from consideration.

Potential Effects

Dredge material disposal may cause increased turbidity, destruction
and displacement of benthos, and contaminant and nutrient release from
sediments. The water methods of disposal are described below.

Open Water Disposal

Depending on the quality of the sediments, open water disposal is
often a good method; however, there are some potential effects associ.atd with
this activity.

Disposing of sediments in open water. In the case of open water
causes increased turbidity, but this is primarily a matter of aesthetic
concern rather than biological damage. However, increased turbidity from
disposal operations may affect fish spawning.

Displacement or destruction of benthic organisms will result from
open water disposal. These organisms will be particularly susceptable in the
larval stage, or in situations where there is a mismatch of sediment types
(i.e. sand on silt).

Aquatic organisms may take in chemical contaminants from dredged
material. Different types of organisms will take in different quantities of
contaminants (i.e. heavy metals) depending on certain biological and

environmental factors.

Wetlands Disposal

Wetlands have been used as dredge material disposal sites for many
years. It can be one of the least expensive disposal methods if the wetland
is close to the dredging operation.

Recently there has been increased concern about using coastal
wetlands as dredge material disposal sites. Wetlands serve many functions.
They contribute greatly to an area's fish and wildlife resources, serve as
storage spaces for run-off and flood waters, and act as natural filters for
pollutants. The value of low lying wetlands becomes evident when these areas
are filled and then become inundated as a result of above average
precipitation.

In its September 1975 guidelines on the disposal of dredge material,
the Environmental Protection Agency (EPA) described disposal operations in
wetlands as being most severe, and stated that destruction of highly
productive wetlands may represent an irreversible loss of a valuable aquatic
resource. Although individual alterations of wetlands may constitute a minor
change, the cumulative effects of numerous changes often result in an
impairment of the wetland resource.

Upland Disposal

Confined or diked containment of dredged material as an alternative
for disposal should also be considered. Confining contaminated material can
be an environmentally sound and preferred alternative; however, there are
reasons why confined disposal may be less effective in protecting water
quality or organisms.

There is a potential change in the geochemical environment that could
lead to increased release of contaminants to the e nvironment. Difficulty in
retaining the finer grained particles in the chosen environmental setting
could result in release of contaminants to lakes, wetlands, or small streams.
Confined facilities result in a permanent change in the physical landscape,
creating aesthetic and alternative land use effects.

Filling

Fill can be defined as earth or any other material placed in a
submerged area for the purpose of erecting structures. This may be to enlarge
the facility, to extend land for the placement of a dock, or to provide more
area for a unit train queue which requires substantial space. Dredging to
obtain fill materials affects the quality of the aquatic environment by
permanently removing large quantities of sand and gravel. The actions
associated with this removal cause the benthic communities at the dredge site
to be destroyed or displaced, quantities of the overlying sediments and sand
to be resuspended, and potential changes in the chemical equilibrium at the

sediment-water interface.

Where dredge material is deposited as fill, some of the material may
flow over retaining dykes and bulkheads. Until this settles, it may adversely
affect water quality. If the dredge material is contaminated, some pollutants
may re-enter the water column. Even unpolluted sediments would have a short
term adverse impact on water quality by causing increased turbidity until the
sediments settle out of the water column. Also, these sediments may exert an
oxygen demand which may harm biota.

Wetlands can be lost because they often have to be filled in areas
where unloading/ transshipment facilities are constructed or expanded. Wetland
vegetation will be destroyed as a result of construction activities, and the
water retaining capabilities as well as other ecologically productive

functions of wetlands will be diminished.

Existing Policy Framework

Federal

0 Rivers and Harbors Act of 1899 as amended 33 USC 501-413

Permits from the Corps of Engineers are required for dredge,
and fill activities in navigable waters; 1970 Amendments
requires confined disposal for polluted dredge material.

0 Federal Water Pollution Control Act Amendments of 1972 as
amended P.L. 92-500

Provides that the Corps of Engineers shall administer permits
for placement of dredged material.

0 National Environmental Policy Act of 1969 (NEPA) P.L. 91-190

Environmental Impact Statements (EIS's) must be prepared for
all major Federal actions significantly affecting the quality
of the human environment. Environmental Impact Assessments
(EIA's) usually done to determine which actions require
EIS's.

State

0 Great Lakes Submerged Lands Acts P.A. 247 of 1955

Regulates, by permit, the use, filling, or sale of submerged
lands within state boundaries.

0 Inland Lakes and Streams Act P.A. 346 of 1972

0 Geomaere-Anderson Wetland Protection Act P.A. 203 of 1979

Regulates, by permit, alterations of wetlands, including
drainage of surface water, construction, dredging and
filling.

0 Shorelands Protection and Management Act P.A. 245 of 1970

Regulates filling activities, land uses and developments
within (1) environmental areas, (2) areas prone to high risk
erosion, (3) areas within the 100-year floodplain.

Potential Mitigation Measures

� Evaluate dredged material disposal options -- all practical alternatives
to discharging materials in the waters of the Great Lakes should be

considered.

� If a confined disposal site is to be constructed it must be designed,
built, and operated in such a way as to achieve maximum effective capacity
and satisfactory effluent quality; for example, surface trenching proved
to be a cheap and effective way of providing natural drainage.

� The regulated discharge of disposal area effluent through a natural marsh
can be effective in removing nutrients.

� Dredge material (particularly dewatered dredge material) has value for
land filling or in construction. Uses of dredge material for road
construction and dike raising should not be overlooked when considering
alternatives.

� Wetland vegetation, soils, and hydrology should not be altered by dredging
or filling to insure that the water retention and ecologically productive

functions of the wetlands will not be diminished.

It may be feasible to place polluted sediments in the innermost areas of
landfills to prevent resuspension in the water table.

0 Dredge spoils can be treated with flocculents to reduce the time it takes
for sediments to settle. This treatment also will minimize the release of

pollutants absorbed by the sediments.

For a site-specific review of dredge disposal operations consider the
following:

� Existing information -- an overview of past dredging and disposal
activities, sediment quality history, and known environmental
sensitivities of the area may expedite decisions on disposal options.

� Physical characterization of sediments -- the physical characteristics of
a sediment provide an indication of the potential for chemical
contamination and assist in identifying possible uses of the dredged
material. (i.e. beach nourishment).

� Chemical characterization of sediments -- the chemical characteristics of
the sediment, when compared to open lake bottom conditions, provide a
relative indication of sediment quality, and the potential for the dredged
material to degrade the substrate at an open lake disposal site.

� Bioassessment of sediments -- to determine the effects of dredging and
dredge disposal on biota -would involve exposure of specified aquatic
organisms to sediments and measuring lethal (acute toxicity) and sublethal
(reproductive impairment) responses.

Evaluation Guidelines

1. What is the purpose of any fill activities -- to enlarge a facility,
provide for a dock, provide area for unit train delivery?

2. Are other locations available that would minimize the need to fill,
particularly if wetlands are proposed for filling?

3. Are wetlands in the area sensitive or highly productive? Have they been
included as an area of particular concern in the coastal management plan?

For related guidelines, see mitigation measures (this section) and
evaluation guidelines for dredging.

P91icy Recommendations

See Policy Recommendation 1 under Dredging.

NEARSHORE CONSTRUCTION

Activity Description

Nearshore facilities include docks, piers, wharves, rail and spur
lines, and auxillary structures for unloading and transshipment of vessels.

Activities relaated to nearshore facilities include:

� Construction -- An increase in surface runoff will result during
construction with the addition of impervious surfaces such as roads and
roofs of buildings. With more impervious surfaces, the ratio of the rate
of runoff to the rate of rainfall will be higher. Increased runoff may
contribute to increased turbidity in the local waterway.

� Materials Delivery and Storage -- Sheet pilings used in construction have
the potential to release heavy metal ions to the env .ironment through
leaching during storage. In addition, small discharges of grease and oil
may be expected from trucks, trains, and heavy machinery during the
delivery and construction operations.

Potential E_ffects

Water quality impacts associated with construction of a coal facility
could have adverse effects on fish by:

(a) lowering the survival rate of incubating eggs because of
increased sedimentation

(b) decreasing the availability of food, by reducing populations of
phytoplankton and zooplankton, and

The release of heavy metal ions from sheet pilings could alter the
water chemistry and adversely affect the aquatic environment.

Any man-made structure influences wildlife using an area. During
construction, nearshore feeding by waterfowl will be affected in areas with

large machinery. The use of the beach by shorebirds may be limited by
construction activities.

Excessi-ve noise from construction may have adverse effects from a
community standpoint. Noise effects is not only a function of maximum noise
levels occurring over a period of time , but also of the magnitude of
fluctuations in levels during that period. The effects of excessive noise
will be discussed later. It is generally concluded that noise from the
operation of construction machinery will have negative effects on the
surrounding area, but will be temporary.

Aesthetically, assembling tall equipment (shiploader, dock hopper)

introduces a vertical element in contrast with the horizontal lines of the
site, which some observers will consider a visual nuisance.

Existing Policy Framework

Federal

0 National Environmental Policy Act of 1969 (NEPA) P.L. 91-290

State

� Great Lakes Submerged Lands Act P.A. 247 of 1955

Regulates, by permit, the use, filling, or sale of submerged
lands within state boundaries.

� Inland Lakes and Streams Act P.A. 346 of 1972

� Geomaere-Anderson Wetland Protection Act P.A. 203 of 1979

Regulates, by permit, alterations of wetlands, including
drainage of surface water, construction, dredging and
filling.

100

� Shorelands Protection and Management Act P.A. 245 of 1970

Regulates land uses and developments within (1) environmental
areas (2) areas prone to high risk erosion (3) areas within
the 100-year-flood plain.

� Soil Erosion and Sedimentation Act P.A. 347 of 1972

Regulates, by permit, erosion effects of development which
involves earth changes in areas adjacent to waterways and in
other areas.

� Michigan Environmental Protection Act of 1970 P.A. 127 of
1970

Provides litigation guidelines for cases involving the
state's air, water, and other natural resources; and mandates
the consideration of environmental factors in administrative
decision-making.

0 Regulations proposed for adoption to Michigan State
Implementation Plan proposed R. 336.1370 - R. 1372

Proposes fugitive dust control programs for Michigan sources.

Potential Mitigation Measures

� Spray critical construction areas and temporary roadways to keep dust

levels low.

� Carefully manipulate drainage from the site. Impoundments will help
remove suspended solids introduced by erosion from construction areas.

� Harm to vegetation and associated wildlife will be minimized by proper
selection of construction areas, replanting selected trees, and by new
planting of native plant species affected by construction.

� Rapid stabilization of disturbed areas will help reduce dust and erosion
problems. For instance, the disturbance caused by construction of a
coal facility could be rectified by sodding, or by importing topsoil and
reseeding (fast cover crop such as rye grass). Such action would reduce
the damage and would serve to stabilize the soil. Also, trees could be

planted to restore the attractiveness of the area.

101

0 Transplanted trees from construction areas to the perimeter can help
screen dust and noise. Also, limiting off-road vehicular traffic will
prevent needless destruction of vegetation in non-construction areas.

Evaluation Guidelines

1. Can the proposed facilities and activities: a) demonstrate acceptable
levels of compatibility with shoreland and water uses; and b) mitigate
anticipated losses of recreational opportunities?

2. Are the facilities and activities sited and designed to avoid adverse
impacts on recreational boating, including marinas?

3. Does the facility construction provide for public access to the water, if
feasible, without interfering unduly with port operation or constituting a
safety hazard?

4. Does the proposal involve development in or adjacent to wetland or other
critical habitat areas? If so, have these been designated as areas of
particular concern in the coastal management plan?

5. Is the proposed shoreland facility located within embayments subject to
poor circulation patterns?

6. Have mitigation techniques been considered for any of the following
purposes: to minimize water or air quality effects, to reduce
recreational or asthetic impacts or to provide protection for habitat and

wildlife resources?

Policy Recommendat ions

1. Where nearshore construction requiring a permit is proposed for an area
adjacent to or otherwise affecting a designated environmental area (under
the Shorelands Management and Protection Act), the project review should
assure adequate protection for the designated environmental area.

102

Care should be taken to consider the potential effects on environmental
areas of problems originating in nearby areas. Lowered air or water
quality may not be restricted to the project area and should be considered
in the review process.

2. The state should continue to complete the designation as "environmental
areas" of all areas so applicable under the Shorelands Management and
Protection Act . Furthermore, interim guidelines for the evaluation of
proposals and plans in candidate areas should be established.

The DNR eventually intends to consider about 300 miles as environmental
areas and has currently so designated approximately 100 miles of
shoreline. Areas which are yet undesignated may have important
environmental value, and mechanisms for proposal evaluation in such sites
should be established so that projects are not held up unnecessarily.

3. The current lack of specificity regarding standards for administering
provisions of the Great Lakes Submerged Lands Act and Inland Lakes and

Streams Act should be corrected.

The regulatory framework focuses on what DNR calls performance standards,
rather that on a policy tactic of defining those uses which will or will
noL be permitLed. Performance standards for project review, however, are
not explicitly delineated.

4. Public access to areas with recreational value should be evaluated in

proposals for the construction of coal related development and plans for

the continuation of such access should be included where feasible.

Facilities should be evaluated with consideration of any preclusion of
recreational access that would be caused by their construction.

5. Aesthetic values should be considered in evaluating proposals for
facilities in or near recreation areas.

103

Facilities which would adversely affect resort or recreation areas in such
ways as view disruption, dust generation, or water and beach related
aesthetic consequences should probably be permitted only under extenuating
circumstances, if at all, or in circumstances where no other feasible or
economically practical areas are available.

6. Coordination between facility operators and various state agencies should
be sought to plan for conducting the most potentially disruptive
operations at the most advantageous time possible from the point of view

of recreation.

Coordination between operators and the state Fisheries Division, for
example, could move towards coal deliveries by vessel during periods when
least disruption of fish spawning or migration may occur.

7. The state and sub-state regional agencies should conduct a review of
vacant urban waterfront areas. Vacant and usable urban waterfront areas,
largely in southern Michigan, may have high value as potential recreation
facilities, and is value should be assessed prior to the permitting of
coal facility development.

8. Whenever possible, proposals for individual dock delivery should be
discouraged where group coal delivery sites are feasible. Such "group
sites" would minimize the need for dredging.

9. Coordination of port planning should be pursued on both state and local

levels.

Currently, planning in many ports in Michigan is largely non-existant or
minimal. Though improvements in this area are occuring, much work needs
to be done if coal traffic increases of the magnitude expected are
realized . Multi-state regional concerns (such as plans for port
development elsewhere in the region) and national policy (e.g., promoting
coal use) should be considered in port planning at local and state levels.

104

FACILITY DEVELOPMENT FOR LAND DELIVERY

Activity Description

Land-delivery facilities include rail spur lines, rail terminals and
access roads. Land clearing and facility development refers to all of the
activities associated with site preparation for unload ing/transshipment
operations including removal of vegetation, excavation and grading,
construction, and final assembly and arrangement of facility components.

Potential Effects

Land Area Required

Land for rail car queueing may take 20 to 30 percent or more of the
area for handling and storage (which might take 25 to 50 acres depending on
reserve storage needs). Generally, water delivery will take considerably less
land than rail delivery.

Land Clearing

The environmental concerns associated with land clearing for
constructing an unloading/ transshipment facility include: air quality, water
quality, erosion, and land-use changes. The major contributing activity
is landscape alteration.

Disturbance and destruction of fields, forests, and woodlots can be
expected with site preparation. Stripping vegetation should be avoided
because it causes compaction and denudation of soils, increases erosion, and
degrades surface water quality due to increased overland flow.

Impacts on coastal wetlands should also be avoided because wetlands
absorb wave energy, help stabilize soils, act as sediment and nutrient traps,
and are a natural filter for pollutants.

105

3:1.

. . . . ....... .

W-7

Many acres of land must be committed to storage at a large coal using facility. (Photograph courtesy of
the Detroit Edison Company)

Dusty condition arising when heavy equipment removes vegetation, will
reduce local air quality because generally the particulate concentrations
around the disturbed areas are in excess of the ambient air quality standards.

The water quality parameter most likely to be affected during land
clearing is turbidity, primarily because of increased surface runoff
associated with land clearing. Also, overland flow will increase because
vegetal cover and rough ground surfaces (which retard the flow) have been
reduced. As development increases, overland flow increases because the water
now flows over smooth surfaces which quickly discharge it to the drainage

channel.

Landscape alteration will also contribute to hazards for wildlife.
During land clearing, wildlife will be less likely to use an area because of
disrupted habitat and increased human activity. For predator species (e.g.,
hawks), any loss of habitat carries with it a loss of hunting grounds, and a
loss of food . Most wildlife species do not tolerate crowding and the end
result is a decrease in wildlife populations.

The aesthetic impact is a subjective area in which it is difficult to
establish standards to suit everyone. There is a wide range of opinions to be
recognized. Strong objections from some people can always be found on an
aesthetic basis and this should be considered a social cost. Generally, any
preparation of the site for construction (removal of vegetation, leveling of
topography) will cause aesthetic concern.

Facility Development

Development of coal unloading facilities may lower water quality and

raise erosion rates and noise levels.

Sheet pilings used in construction can release heavy metal ions to
the environment through leaching, during storage. In addition, small
discharges of grease and oil may be expected from trucks, trains, and heavy
machinery during delivery and construction.

107

Surface runoff will increase during construction because of
additional of impervious surfaces such as roads and roofs of buildings. With

more impervious surfaces, the ratio of the rate of runoff to the rate of
rainfall will be higher. Increased runoff may contribute to turbidity in the
local waterway.

An increase in local employment will result from construction
activities, a positive but temporary situation for local communities. Since
housing for these employees would be dispersed, the effects of absorbing new
employee families not already living in the area is expected to be minimal.

Existing Policy Framework

Federal

� National Environmental Policy Act of 1969 (NEPA) P.L. .91-190

� Clean Air Act as amended P.L. 91-604 as amended by P.L.
92-157, P.L. 93-15, P.L. 93-319, P.L. 95-95

Directives issued under Title I of the Act have mandated
fugitive dust mitigation provisions in State Implementation
Plans (SIP's) for some areas.

� Noise Control Act of 1972 P.L. 92-574

To protect health and welfare ambient noise levels are
recommended; they may become standards for facilities
regulated by state and local governments.

State

� Soil Erosion and Sedimentation Act P.A. 347 of 1972

Regulates, by permit, erosion effects of development which
involves earth changes in certain areas.

� Michigan Environmental Protection Act of 1970 P.A. 127 of
1970

108

Provides litigation guidelines for cases involving the
state's air, water, and other natural resources; and mandates
the consideration of environmental factors in administrative
decision-making.

Potential Mitigation Measures

0 Spray critical construction areas and temporary roadways to help keep dust

levels low.

0 Carefully manipulate drainage from the site. Impoundments will help
remove suspended solids introduced by erosion from cleared areas.

0 Damage to vegetation and associated wildlife will be minimized by proper
selection of construction areas, replanting selected trees, and by new
planting of native plant species affected by construction.

0 Rapid stabilization of disturbed areas will reduce dust and erosion
problems. For instance, the disturbance caused by land clearing could be
rectified by sodding, or by importing topsoil and reseeding (fast cover
crop such as rye grass) . Such action would reduce the environmental
impact of land clearing and would serve to stabilize the soil. Also,
trees could be planted to restore the attractiveness of the area.

0 Transplanting trees from cleared areas to other areas will help screen
dust and noise. Also, limiting off-road vehicular traffic will prevent
needless destruction of vegetation in non-construction areas.

0 Locate the structures in areas where vegetation is in early or
mid-successional stages (fields and young wood-lots) will hasten the
natural revegetation process.

0 Reduce the area for equipment laydown and access roads to lessen effects

on wildlife.

0 Actively manage the area for wildlife. For instance, stationary equipment
can create increased roosting and nesting sites for gulls, pigeons, and

swallows.

109

0 Reclaim disturbed areas with wildlife in mind. Planting food plants,
establishing water holes, and creating nesting sites will help keep

wildlife in the area.

0 Sound levels during construction should be monitored to determine the
effects of noise and to identify and control noise from those activities
which may significantly affect sound levels.

0 Coastal Energy Impact Program funds should be made available to
communities with significant demands placed on them by a concentration of
construction employees' families.

Evaluation Guidelines

1. Has siting, construction and operation of new facilities for highway or
rail delivery of coal been carefully evaluated by DNR in close cooperation
with the State Department of Transportati-on and affected local entities?

2. Has the state review of the project proposal emphasized adequacy and
completeness of the prepared environmental impact statement(s) it required?

3. If new facilities for rail or highway transport are proposed, has the
applicant presented sufficient evidence to demonstrat need for the
facilities and inadequacy of existing transportation systems?

4. Have efforts been made to reduce adverse consequences, including those on
cultural and historic resources, critical habitats, agricultural lands and
community land uses.?

5. What impact could the proposal have on:

a. restricting public access to the waterfront?
b. precluding future shoreland industrial development options?

6. Have mitigation techniques for anticipated adverse impacts of the proposed
facility been considered?

110

7. Has there been coordination with local community planning for land use and
transportation?

8. Is any new housing expected to be concentrated in surrounding communities
for new construction employees families? If so, can water, sewer, police,
fire, school and other public services handle any increase in demands?

Policy Recommendations

No policy changes are recommended.

OPERATIONS FOR ON-SITE HANDLING OF COAL

Activity Description

The handling operation includes coal loading, coal unloading, and the
transfer of coal for storage or use.

Potential Effects

Handling

The primary environmental effects of coal handling are the land area
requred and dust generation.

Land Area -- Land is required for the coal handling system and for
storage. In the Great Lakes region, a six-month reserve supply is usually
stored to allow for winter disruption of shipping. Land area utilized
will vary from facility to facility. A 1000-MWe coal-fired plant needing
90 to 180 day reserve will require 25 to 50 acres, respectively, for coal
storage. Depending on the layout of the unloading, handling, storage and
coal-using areas and whether the coal arrives by water or rail, this land
area may be immediately along the coast or inland. If coal is primarily
delivered by lake vessel, more storage area will be required because the
shortened shipping season creates the need to stockpile coal while the

lakes are ice-covered.

ill

Conveyor system -- several conveyors are used to transport coal within the
transshipment/unloading facility. In all new facilities conveyors will be
covered, but minor fugitive dust emissions may still result from spillage
at major transfer points. In older facilities the conveyor system may not
be totally covered, and is anticipated (along with the storage pile) to be
a primary source of fugitive dust.

Unloading (receiving) Bins -- Bins into which trucks dump coal, with
feeders underneath to transfer coal to a conveyor, are very common.
Fugitive dust can escape where trucks dump at the top and where the
feeders empty the coal at the bottom. The dust generated is substantial
if the coal is dry and if there are high winds.

Rotary Car Dump -- Unit trains are unloaded by a rotary car dump. The
system is designed so that the entire coal car plus a portion of the track
can be rotated 180 degrees. The coal is then dumped into a hopper below
the track. Dust will be generated by the dumping. The rotary car dump is
often enclosed in a building, which helps to contain most of the dust.

Transfer House -- A transfer house is a structure located at major
transfer points such as the main conveyor to radial stacker. Because
these houses are enclosed, fugitive dust associated with their use will be

minimal.

Stoc@pile -- The stockpile is established by overhead conveyors which
carry coal from the load ing/un loading stations. The conveyors feed coal
into telescopic chutes which discharge it onto piles. The coal piles
built up at the chute discharges are placed in the stockpile areas by
bulldozers, which are also used for compacting the coal to reduce the risk
of spontaneous combustion. The dust here comes from the loadout chutes,
associated conveyor system, and from the bulldozer grooming operation.

Rotary Plow Feeder -- Coal from the stockpile is reclaimed for loading
onto ships or unit trains by the rotary plow feeder. The rotary plow
feeder moves horizontally along the top of a reclaim tunnel, sweeping coal
through a gate onto a conveyor belt below. A system of conveyor belts

112

carries the coal to a surge bin which feeds the shiploader or loading
station Coal dust is generated here at the major transfer points;
reclaim tunnel to conveyor belt, conveyor belt to surge bin, and surge bin
to shiploader or loading station.

Loading Stations -- A loading station is a structure for loading a unit
train. The station is comprised of a surge bin located above the track,
large enough to hold incoming coal while cars are changing, a loadout
chute, and a control room. Another type of loading station involves a
large silo, under which the unit train moves for unloading. Some type of
station will be located everywhere unit trains are loaded. Dust will be
generated here by coal dropping into the cars during loading for
transshipment .

Ship Loader -- The ship loading operation is a major source of coal
particulates. The shiploader is an enclosed system which operates over
the ship and lowers a telescopic chute into the hold of the vessel to
complete the loading operation. During loading, some coal is released
into the air from the loading chute and from the conveyor. Together these
two components constitute a point source of windblown material close to
the water . The dust from vessel loading is important locally since it
could produce high particulate concentrations in the waterway over short
periods of time. In the short run these particulates will settle out near
the dock area. Eventually the material will be transported downstream by
resuspension from ships. A significant input of coal particulates from a
facility to a waterway may occur when coal is trapped in the ice cover and
then transported to the harbor during the spring ice break-up.

The ship loading and unloading operations will contribute to other
environmental problems. Near shore coal handling will affect aquatic
ecosystems by causing increased turbidity from spillage. This increase
will cause a decrease in light penetration, which will reduce the
suitability of the area for aquatic vegetation.

113

Empty unit train cars leave the Rotary Car Dump House where they were individually rotated 180 degrees
emptying their contents onto an under structure conveyor. (Photograph courtesy of the Detroit Edison Company)

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A rotary plow feeder is taking coal from a pile and "feeding" coal to a conveyor. (Photograph courtesy of
the Detroit Edison Company)

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Storage piles are continuously groomed by earthmovers. The coal pile near the center of the photo is being
formed by coal leaving the termination point of a conveyor system-possibly bringing newly delivered coal for
storage. (Photograph courtesy of the Detroit Edison Company)

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A lake vessel unloads onto an open pile while earth movers and coal carrying trucks transfer the newly
arrived coal to storage areas. (Photograph courtesy of the Detroit Edison Company)

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711

A lake vessel unloads into an enclosed hopper. This system is likely to produce less fugitive dust than the
open-pile unloading. (Photograph courtesy of the Detroit Edison Company)

Accumulations of coal on the harbor bottom due to spillage will
alter the composition of benthic fauna. The effects of coal on the harbor
bottom will include a reduction in density, diversity, and dominance by
tolerant organisms .

in addition, the most significant noise sources associated with
coal transshipment/unlo,ading facilities are the onshore ship loading
machinery and the on-board coal handling machinery. This machinery
produces continuous noise which will be maintained at a steady level during
each four hour loading/unloading operation. The enclosed conveyor system's
contribution to noise will be practically imperceptible.

Employment -- Once the coal handling and storage areas have been
constructed, employment will shift from construction to operation and
maintenance work forces. Persons with many different levels of skills
and training will be required. Operation and maintenance employment
for coal handling and storage may range from 30 to 40 persons for a
1000-MWe coal-fired electrical generating plant up to 90 to 100 persons
for a large 3000-MWe plant. It is expected that employees' families
would reside throughout an area rather than being concentrated in one
location. Increased stable employment that this would offer would be a
positive effect.

Storage

Stockpiles are used widely at transshipment /unloading facilities as
well as at user sites (utilities, industry). Users of coal often maintain 60
to 90 day supplies. The two most significant impacts associated with coal
storage are fugitive coal dust and spontaneous combustion. For land area and
employment effects, refer to the section on "Handling" above. Several
operations cause fugitive dust emissions from the storage area. The Midwest
Research Institute evaluated the four major emission producing activities and
their approximate relative contributions as follows:

- loading onto piles 12%
- equipment and vehicle movement in storage area 40%

119

- wind erosion 33%
- loadout from piles 15%

Loading onto Piles -- The dust generated from coal loading is caused by
dumping coal from the overhead conveyor to the coal pile.
Concentr at ions are usually less significant than the amount of coal
dust resulting from the grooming operation of the coal pile.

Equipment and Vehicle Movement in Storage Area (grooming and
reclaiming) -- Grooming refers to compacting a coal storage pile with
bulldozers or caterpillar tractors to reduce the risk of spontaneous
combustion. Reclaiming refers to moving the stockpile around with
bulldozers and front end loaders to reduce of dead space and to reclaim
the coal for loading onto a conveyor belt or rotary plow feeder.
Grooming and reclaiming go on constantly, and hence these operations
appear to be the most consistent source of coal dust.

Although a source of dust generation, grooming lessens the risk of
spontaneous combustion; as the risk is reduced when coal is compact. The
compaction tends to reduce the rate of moisture movement through the pile, and
to increase the quantity of water which can be retained by the pile.
Spontaneous combustion can release atmospheric contaminants such as sulfur
oxides, hydrocarbons, and nitrogen oxides.

Minor topographic changes will occur as a result of the cycle of
stockpile building and reclaiming. The major topographic change will be
compaction of the soil under and around the stockpile which can possibly cause
some minor changes in drainage patterns.

Fugitive dust from the stockpile is also the major source of coal
particulates for a waterway. Some of this dust comes directly from wind
action on the coal pile. However, much of it is caused by the grooming
operation. Increased coal dust in the waterway will increase turbidity and
may alter the pH of the water.

120

Wind Erosion -- Even without grooming and reclaiming operations the
coal pile will generate particulates at low levels on an almost continous
basis, due to wind. Coal dust blowing from storage piles onto adjacent land
areas-could cause disease of trees and other plants by clogging leaf pores and
coating leaf surfaces, and general aesthetic degradation of the area. Sudden
changes in wind direction will give rise to visually dense dust plumes. Coal
dust blowing from storage piles may also effect wildlife through: (a)
ingestion of plant material coated by dust, (b) discoloration of fur and
feathers or allergic reactions to coal dust,, and (c) possible heavy metal
uptake through plants, as a result of coal leachate from storage piles which
may affect the soil and groundwater.

Existing Policy@Framework

Federal

� Clean Air Act as amended P.L. 91-604 as amended by P.L.
92-157, P.L. 93-15, P.L. 93-319, P.L. 95-95

Ambient air quality standards have been set for SO 21 TSO,
NO 21 CO, HC, and 0 X; more are being considered.

New Source Performance Standards (NSPS) apply to coal-fired
boilers and regulate SO NO , and particulates. Lower
2$
emission levels are being consiLred, as are regulations for
small particulates. Stricter standards specific to FBC may
be established.

Standards for hazardous pollutants regulate mercury,
beryllium, and asbestos.

NSPS and regulations for the prevention of significant
deterioration may affect plant siting.

Best Available Control Technology (BACT) may be required when
locating in "clean" regions. BACT will be determined on a
case-by-case basis.

Lowest Achievable Emission Rates (LAER) may be required when
locating in non-attainment regions.

� Resource Conservation and Recovery Act of 1976 P.L. 89-272

Solid waste disposal must comply with most stringent air and
water standards; monitoring is required.

121

New regulations will be developed in 1-2 years for a Federal
hazardous waste handling permit system and state programs for
non-hazardous solid wastes.

State

� Michigan Environmental Protection Act of 1970 P.A. 127 of
1970

Provides litigation guidelines for cases involving the
state's air, water, and other natural resources; and mandates
the consideration of environmental factors in administrative
decision-making.

� Clean Air Act as amended P.L. 91-604 as amended by P.L.
92-157, P.L. 93-15, P.L. 93-319, P.L. 95-95

Directives issued under Title I of the act have mandated
fugitive dust mitigation provisions in State Implementation
Plans (SIP's) for some areas.

� Noise Control Act of 1972 P.L. 92-574

To protect health and welfare ambient noise levels are
recommended; they may become standards for facilities
regulated by State and local governments.

Potential Mitigation Measures

Handling

� Receiving Bins -- Receiving bins should be designed with a semicircular
backstop to prevent coal spillage from the bin into the waterway, and
to prevent the wind from blowing coal dust out of the bin.

� Conveyor System -- The main conveyors should be completely enclosed to
reduce dust blown into the atmosphere. Also, conveyor to conveyor
transfer points should be enclosed. Any dust generated during transfer
will be ventillated to baghouse dust collectors.

� Unloading Bins -- Emissions should be controlled at the bottom with

sprays or a dust collector with bags. Scrubbers are sometimes used.
Enclosure of the bin on three sides and with a sloping roof will
contain the dust in many cases. If supplemental control is required,
curtains can be hung to partially close the opening when a truck is

122

dumping. A dust collector (baghouse collector) can then be used.
0
Sprays do not function well at bin locations because the areas are
large and the dust generation is violent and intermittent.

� Loading Stations -- A loadout chute can prevent large amoun'ts of dust
and spillage when coal is transferred to cars in high volumes. The
chute is a large, vertical, telescopic device that travels to the car
bottom with each car, raises with the coal as the car is loaded, stops
and crowns the car, stops the flow of coal as cars are changed, and
repeats the cycle. . This helps prevent the escape of dust because the
chute remains in contact with the coal in each car during loading.

� Rotary Car Dump -- The operation should be enclosed in a build-ing, and
dust emissions should be ventillated to baghouse collectors.

� Stacker/Reclaimer -- Fugitive dust emissions generated during the
stacking and reclaiming operations should be ventillated to a baghouse
collector or controlled by spraying.

� Dust Control System -- The major dust control technique be spraying,
which should be done through spray headers at the four transfer points
where dust generation is most likely to occur: (a) the top of the
receiving bin, (b) receiving bin to conveyor, (c) conveyor to radial
stacker, (d) head pulley radial stacker (transfer house).

� Advances in coal handling technology for both vessels and shoreside
facilities could reduce the potential for spillage and dust. This
technology changes rapidly.

Storage

Methods for controlling dust from coal storage piles are limited in
effect or are very expensive. However, a number of methods will at least
partially alleviate the impact of dust from a coal storage pile.

0 As a minimum, coal piles should be capped with larger sized coal to
prevent the loss of fines due to wind.

123

� Bituminous coal should be tightly packed to prevent fires (spontaneous
combustion).

� Some installations use concrete silos, which hold up to 10,000 tons and

control dust effectively.

� An earthen impoundment can help contain and control coal dust from a
coal pile.

� All semi-permanent storage capacity should be established on the
periphery of the storage pile. The exterior face should then be
treated for aesthetic considerations. The peripheral reserve storage
will act as a windbreak completely surrounding the storage pile.

� The effects of grooming the coal pile with large bulldozers should be
closely examined. All dozers should be equipped with wet suppression

systems.

� The design of the fans on bulldozers should be changed to minimize the
blowing of coal dust into the air.

� All active portions of the pile should be sprayed. A major portion of
these particulates can be controlled by water sprays.

� Settling basins should be used to mitigate runoff.

Evaluation Guidelines

1. Can new coal facility areas be located in areas downwind of intensive
public use and other outdoor recreation, residential and retail business
development?

2. Has coal dust generation at stockpiles and at points of unloading and
conveyance been minimized to the extent feasible, using the best available
technology?

124

3. Can appropriate mitigation techniques be implemented in conjunction with
project approval?

4. What are the climatic and wind conditions at the project sites?

5. Is land available on the site for expansion of stockpiling if necessary?

6. Will land area needs for storage of coal conflict with other land uses?

7. Have measures been taken to avoid shoreline placement of coal or
stockpiling where feasible?

8. Has a buffer zone been assured for protection of shoreline areas from
facility operation?

9. Are stockpiling and operations activities proposed in areas consistent
with state environmental objectives for protecting critical habitats?

Policz Recommendations

1. Rules and regulations concerning the mitigation of fugitive dust
generation during the grooming of active storage piles should be
promulgated and implemented to whatever extent practicable.

Current proposed fugitive dust regulations for the State of Michigan,
though including coverage of inactive storage piles, do not regulate dust
generated during the performance of such activities as coal removal from
piles or coal compaction. Though complete elimination of such dust would
be impossible, mitigation techniques for its minimization do exist.

2. Nonpoint source controls on coal pile runoff should be required for
existing as well as proposed facilities.

Though the exact impact of coal dust on aquatic and other runoff effected
ecosystems has not yet been conclusively determined, mitigation techniques
such as the construction of sedimentation basins would serve as relatively
low cost preventives.

125

SUPPORTING APPENDICES

Page No.

Policy Recommendations for Michigan Coal Facilities . . . ... . . A-1

Projection s
Historical Coal Movement in Michigan Ports, Waterways
and Rail Lines . . . . . . . . . . . . . . . . . . . . . . . . B-1
Results of the Coal Facility Review . . . . . . . . . . . . . . . C-1
1. Michigan . . . . . . . . . . . . . . . . . . . . . . . . . C-9
2. Great Lakes States . . . . . . . . . . . . . . . . . . . . C-16
Michigan Power Plants . . . . . . . . . . . . . . . . . . . . . . D-1
Factors and Policies Affecting Future Coal Use . . . . . . . . . . E-1

The Coal Production-Consumption Cycle . . . . . . . . . . . . . . F-1

Environmental Effects
Environmental Effects -An Overview of the Chemical
and Physical Characterization of Coal . . . . . . . . . . . . . G-1
Comprehensive Mitigation Strategy . . . . . . . . . . . . . . . . H-1

Policy Review
Review of Michigan and Federal Policies . . . . . . . . . . . . .
1. Energy Policy and Coal . . . . . . . . . . . . . .. .. . . . 1-8
2. Transportation Laws and Programs . . . . . . . . . . . . . 1-15
3. Environmental Laws and Programs . . . . . . . . . . . . . 1-36
4. Recreation Planning . . . . . . . . . . . . . . . . . . . 1-86
5. Relationship of Federal and State Coastal Zone
Management Programs to Coal Transportation . . . . . . . 1-89
6. Port Development in Michigan . . . . . . . . . . . . . . . 1-96
7. Organization of Michigan DNR . . . . . . . . . . . . . . . 1-99

Matrix of Michigan Energy Policy . . . . . . . . . . . . . . . . . J-1

REFERENCES

APPENDIX A

POLICY RECOMMENDATIONS RELATED TO MICHIGAN COAL FACILITIES

I. ENERGY

State Policy

1. The State of Michigan policy on future coal use should
recognize (1) the current significant use of coal in the
state., and (2) the need for diverse energy sources in the
Long-run to provide a stable economic-industrial base not
threatened by dependence on any one source.

II. TRANSPORTATION
Waterborne Transport

2. Programs and regulations should increase the cooperation
between environmental agenc-&es and the United States
Coast Guard to minimize onshore vessel impacts.

Variable factors such is vessel speed and route may substantially
affect such environmental impacts as shore erosion and suspension of
particulates. Coordination between agencies capable of identifying the
sources of these problems and agencies such as the USCG, with enforcement
authority under the Ports and Waterways Safety Act, could be greatly
beneficial.
3. Rules and regulations should be developed under the the
Clean Air Act to deal with emissions from coaZ-fired
transport vessels.

Experts in transportation indicate that coal as a power source
for lake vessels may be significant in coming years. Emissions from this
source are not currently regulated under the Clean Air Act.
Motor Carrier Transport

4. State and regional planning and policy agencies shoutd
update Environmental Protection Agency regulations
concerning allowable motor carrier noise.

As new technology has been developed in recent years with respect
to motor carrier noise emissions,, tighter regulations in the form of lower
allowable decibel limits may now be achieved. These regulations should
probably only apply to new trucks to prevent the creation of economic
hardships on current operators and must be promulgated by the EPA due to
the preemptory nature of the Noise Control Act of 1972.

A-1

5. State and regional planning and policy agencies should
work towards Environmental Protection Agency inclusion of
truck noise emissions within EPA 's raityard noise
standards which are currently being developed.

Loading and unloading coal from trucks may produce significant
noise levels. To adequately regulate rail yard noise as a whole, truck
noise should be included.
6. State and regional planning and policy agencies should
cooperate to set uniform weight limitations for
interstate coal trucking.

Because state regulations differ concerning vehicle weight
restrictions, all roads traveled by coal transporting trucks may not be
adequately designed, and road surface damage may result. Cooperation in
setting weight regulations may lead to more uniform standards and roads
better able to withstand frequent transport of heavy commodities such as
coal.
Rail Transport

7. Rules and regulations concerning the implementation of
fugitive dust mitigation techniques during rail transport
should be promulgated and enforced.

Because fugitive dust is produced by rail transport of coal,
regulations such as those proposed for truck transport is often an
interstate activity, federal regulations in this area may be most
effective.
8. State of Michigan laws regulating the allowable period of
railroad crossing blockage by trains should be amended to
minimize the greater potential community disruption of
longer and slower moving coal transport trains.

Studies have shown that when pre-train delay times, actual
blockage times, and post-train traffic dispursion times are taken into
consideration, periods of train interference with community activities may
far exceed the five minute limit imposed by Michigan laws. Michigan
statutes should therefore be amended in such a way as to minimize the
total traffic delay times caused by the passage of a train through a
community. The growing use of unit trains in coal transport may make the
need for the amendment of such laws acute.

9. Low cost solutions to rail interference with community
activities should be examined by state and regional
planning agencies. These could incZude both structural
and non-structural projects, such as modification of
operating practices, railroad facilities, community
transportation facilities, and community development
patterns.

A-2

III. FACILITY DEVELOPMENT AND OPERATION
10. The state Departments of Natural Resources and
Transportation should prepare a coordinated., flexible,
long-range dredging and dredge disposal plan for coal and
other goods and commodities transport. Factors to
include are port needs, water quality considerations,
fish and wildlife habitat effects, other state priorities
with respect to the need for and location of deepwater
ports.

11. Proposals for the improvements such as dredging should
include consideration of alternatives, such as the
utilization of integrated tug barges.

Such alternatives, where feasible, would use transport modes less
dependent on deep channels and would decrease the need- for initial and
maintenance dredging.
Stockpiling

12. Rules and regulations to mitigate fugitive dust
generation during the grooming of active storage piles
should be promulgated and implemented to whatever extent
practicable.

Proposed fugitive dust regulations for Michigan, though including
inactive storages piles, do not regulate dust generated during such
activities as coal removal from piles or coal compaction. Though complete
elimination of such dust generation would be impossible, mitigation
techniques do exist.
13. Nonpoint source controls on coal pile runoff should be
required for existing as well as proposed facilities.

Though the exact impact of coal dust on aquatic and other runoff-
effected ecosystems has not yet been conclusively determined, mitigation
techniques, such as constructing sedimentation basins, would be relatively
low cost solutions to potential adverse impacts.
Shoreland Development

14. where a proposed facility or activity requiring a permit
is adjacent to or otherwise impacting on a designated
environmental area, as provided for wider the Shorelands
Protection Management and Act, the project review should
assume protection for the designated environmental area.

Care should be taken to consider the potential effects on
environmental areas of impacts originating in nearby non-environmental
areas. Impacts on air or water quality, may not be restricted to
undesignated areas, and should be considered in the review process.

A-3

15. The state should complete the designation as
flenvironmental areas" of all areas so applicable under
the Shorelands Protection and Management Act.

The DNR intends to consider about 300 miles for designation as
environmental areas and has currently designated approximately 135-140
miles of shoreline. Areas yet undesignated should be protected by
provisions contained in Section 404 of the Federal Water Pollution Control
Act and the Michigan Wetlands Protection Act (P.A. 203 of 1979).
16. Yhe current lack of specificity regarding standards for
administering the Great Lakes Submerged Lands Act and
Inland Lakes and Streams Act should be corrected.

The regulatory framework focuses on what DNR calls performance
standards, rather than on defining those uses which will or will not be
permitted. Performance standards for project review, however, are not
explicitly delineated.

It should be noted that the Department of Natural Resources is
currently involved in making rule changes to remedy this problem, though
the language of these rule changes is not yet available.
Recreation/CoaZ Facility Interaction

17. Public access to areas with recreational value should be
considered in proposals for the construction of coal
related development, and continuing such access should be
included where feasible.

Fac i I it ies should be evaluated with consideration of any
preclusion of recreational access created by their construction.
18. Aesthetic values should be considered in evaluating
proposals for facilities in or near recreation areas.

Facilities which would adversely affect resort or recreation
areas by view disruption, dust generation, or water and beach related
aesthetic impacts, should be permitted only under extenuating
circumstances, if at all, or in circumstances where no other feasible or
economically practical areas are available.
19. Coordination between facility operators and state
agencies should be sought to plan for conducting the most
potentially disruptive facility operations at the most
advantageous time possible from the point of view of
recreation.

Coordination between operators and the staLe Fisheries Division,
for example, could schedule coal deliveries by vessel during periods least
disruptive of fish spawning or migration.

A-4

20. Vacant and usable urban mterfront, largely in southern
Michigan, may have high recreational value, and this
should be assessed prior to permitting coal facility
development.

IV. PLANNING AND GENERAL RECOMMENDATIONS
21. Appropriate agencies should study the effects of coal and
coal dust on the aquatic environment.

Such studies should concentrate on the level of chemical
reactivity of coal in water, any biological effects on aquatic
communities, aesthetic effects of coal in water, and increased dredging
requirements due to significant coal dust input through runoff.
22. Coordination and cooperation among agencies should be
pursued in reviewing permit applications or project
proposals for transshipment and handling facilities, as
the complex interactions of these projects require an
integrated approach.

23. Coordination of port planning should be pursued on both
state and local levels.

Planning in many Michigan ports is -largely nonexistant or
minimal. Though improvements in this area are occurring, much work needs
to be done if coal traffic increases to the magnitude expected.

Incentives for local port authority development are currently
present within P.A. 639 of 1979, however this Act leaves the initiation of
port development projects largely up to local authorities and may not
provide the necessary level of state coordination. The Michigan
Governor's Port Council is currently developing 'criteria for approving
local port authorities.
24. Planning and permit processes for coal unloading and
transshipment facilities should be integrated with
planning and permitting of energy and industrial
facilities on a comprehensive basis.

Coal unloading and transshipment facilities are, in all cases
examined, associated with and located near a coal using facility.
Planning for the two facilities must be done together. Energy-related
industrial facilities planning must consider all feasible types of fuel
and energy sources and locations. The Michigan Environmental Review Board
should consider requiring for state environmental impact statements that
all feasible alternatives to energy projects be considered, even those
beyond the legal purview of the organization involved, so that the public
interest i-s served by the least costly approach to energy delivery to the
end user . Long-range productivity of the firm, as well as the end user
should be factors in this evaluation.

A-5

25. Coal transportation, facility development and facility
operation planning should be part of an overall energy
facility siting process.

Such a process should be comprehensive in naLure and comprise
part of an overall state energy plan or policy. Coordination among such
groups as the public utilities commission, air and water pollution control
agencies, local zoning boards, and other state and local interests could
also be inherent in such a process.

Using existing permit and review processes of the Department of
Natural Resources, the Public Service Commission, and other commissions
and agencies, the state should develop a coordinated siting process. Two
possible approaches include (1) establishing an energy facility siting
board of commission and department heads to coordinate and permit energy
facilities, or (2) designating a lead agency to coordinate the review and
permitting of energy facilities with other staLe commissions and agencies.
These coordinated review and permitting processes should incorporate a
planning funct.ion to anticipate future facility needs.
26. In order to provide a comprehensive approach to
mitigating the potential effects of increasing coal use
and provide further benefits of existing coal use, the
state and national coastal zone management programs
should consider using coastal energy impact program (CEIP
funds to ameliorate the effects of coal facility
expansion, and using permit renewals to enhance existing
coal facilities.

Specifically, the CEIP funds could be used to assist communities
during construction of a project or provide public access and facilities
in areas of heavy demand. At existing coal unloading and using sites, the
state could work with the coal transporting or using company in the permit
renewal process to provide additional shoreline access. CEIP funds might
then be used to provide boat launches, fishing piers and other
recreational features. These features should be provided in a way that
does not conflict with commercial uses of the area nor creates safety
problems for small boat operators,

A-6

APPENDIX B

HISTORICAL COAL MOVEMENT IN MICHIGAN
PORTS AND WATERWAYS

SUMMARY

PURPOSE

For a study of the potential implications of increased coal movement
in Michigan, historical information may be valuable. Examining past
conditions which may have approximated those expected in years to come could
assist us in making projections about the type and degree of facility changes
necessary to adapt to new increases, as well as produce clues about ways of
managing future demands. Answers to questions such as, what were the peak
years of coal movement in Michigan?; what were the heavily used ports and
waterways during these years?; and what were the trends of coal movement in
various ports and waterways over time?, may provide indications of the ability
of ports and waterways to move and receive large quantities of coal.
Historical data, however, is at best speculative when being applied to future
projections, but may serve to spawn questions for further research about the
applicability of past trends.

RESULTS

For this historical study of waterborne coal movement in Michigan,
data was examined for the years 1955 through 1977. This period contained both
years of peak coal usage in the Great Lakes region such as 1956 and 1966, as
well as more recent years of lower usage. The source of this information was
Waterborne Commerce of the United States, compiled annually by the U.S. Army
Corps of Engineers. Data was collected on receipts and shipments of coal to
and from twenty-four Michigan ports, as well as receipts, shipments, and
through traffic for five Michigan waterways.

Several gaps in data exist within the twenty three-year period for
some ports and waterways, as do some anomalies in reported data (see Port of
Detroit, 1972). These may be caused by reporting or surveying deficiencies,
but do not affect the overall usefulness of our study. The reader should also
note that because distinctions have been made between receipts, shipments, and
through traffic, substantial overlap or double counting of coal may have
occurred, and totaling the various categories would exaggerate total movement
figures.

The major receiving ports are divided into three size-related groups
on the basis of 1970 tons received. Within each group, ports are classified
as increasing, decreasing, or stable in their coal receipts for the 1970-1977
period. Values for 1970 and 1977 tonnages have also been included in the
following tables, as have rotations indicating 1955-1977 trends.

B-1

TABLE B-1

PORT TRENDS 1970 - 1977

RECEIPTS
SMALL 0 -__100,000 TONS/YR.

1970 INCREASING 1977 1970 DECREASING 1977

*(72,970) Holland (157,809) *(72,272) Traverse City (62,416)
*( - ) Presque Isle (707,475) +(75,604) Calcite (11,448)
*+(9,436) Gladstone (24,160) *+(204) Frankfort
*(38,824) Monroe (1,063,578)

1970 STABLE 1977

*(14,956) Cheboygan (18,872)
*(7,352) Ontonagon (9,347)

MEDIUM 100,000 - 500,000 TONS/YR.

1970 DECREASING 1977 1970 STABLE 1977

+(274,656) Escanaba (154,722) #+(216,243) Manistee (125,214)
*(316,268) Harbor Beach (268,318) +012,543) Petoskey Penn. (122,404)
+(270,879) Luddington (35,159) Dixie
*(111,489) Grand Haven (87,682)
*(149,382) Charlevoix (39,936)
+(106,008) Menominee (83,697)

LARGE 500,000 TONS/YR. AND UP

1970 DECREASING 1977 1970 STABLE 1977

+(9,014,448) Detroit (6,275,792) *+(1,642,800) Muskegon (1,553,742)
+(1,566,838) Saginaw River (158,382)
*+(790,596) Alpena . (497,869)
*(629,292) Marquette (351,388)

KEY - * generally increasing 1955-1977
+ generally decreasing 1955-1977
*+ generally stable 1955-1977
unusually high year

B-2

The above tables make it clear that Michigan ports have generally
been decreasing their receipts during the 1970-1977 period. The only ports
which do not either decrease or remain relatively stable during 1970-1977 are
those in the "small" category. For this reason, increases made by these ports
have not greatly affected the overall picture. The most significant changes
in coal receipts can be seen in the "large" ports of Detroit and the Saginaw
River. Decreases in the receipts of these ports color the entire picture of
Michigan receipts.

The period of 1955 through 1977 displays similar results. Small and
medium ports however, do show more increases over the longer period than over
the 1970-1977 span. The large ports have generally decreased receipts over
this, time, as they have in recent years. It appears clear, when data from
peak and low receipt years is examined, that the largest ports fluctuate most
dramatically and greatly affect the annual receipt totals.

Trends in coal movement through Michigan waterways are displayed in
the table below:

B-3

TABLE B-2
WATERWAY TRENDS 1970-1977

RECEIPTS AND SHIPMENTS

1970 DECREASING 1977 1970 STABLE 1977

+(417,159) St. Mary's River (28,589) *+(75,179) Keweenaw (68,483)
*(4,808,760) St. Clair River (1,557,919) Waterway
+(9,014,448) Detroit River (6,800,706)

THROUGH TRAFFIC

1970 INCREASING 1977 1970 DECREASING 1977

*+(3,723,106) St. Mary's River (8,205,491) +(20,928,412) Detroit River (12,891,683)

1970 STABLE 1977

+(40,603) Keweenaw Waterway #(73,844)
+(12,604,693) St. Clair River (11,405,652)
+(678,329) Gray's Reef Passage (417,800)

KEY - * generally increasing 1955-1977
+ generally decreasing 1955-1977
*+ generally stable 1955-1977
unusally high year

B-4

During 1970-1977 waterways have generally decreasing or stable coal
movement. The exception to this trend is the St. Mary's River which has
recently increased its through traffic. During 1955-1977, a more clearly
decreasing trend in coal movement can be observed. The peak years of 1956 and
1966 show marked increases in tons moved through the waterways, as would be
expected, indicating increased waterway use during periods of high coal use.
The St. Clair River and Detroit River seem to have been handling the most
traffic in recent years, as well as during the longer period examined.
Indications are, however, that all five waterways could accomodate more
traffic than they currently do.

B-5

TABLE B-3
RECENT PAST HISTORY OF COAL RECEIPTS AND SHIPMENTS IN
MICHIGAN HARBORS & PORTS

PORTS 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967

Atpeoa Harbor 593,893 609,583 672,567 510,927 670.163 618,494 497,923 555,537 678,446 594,935 699.029 771.152 673.361
Calcite 106,796 152,496 136,138 87,236 89,935 90,577 68,218 75,206 80 289 72,565 92,034 69.343 96,767
Charlevoix Harbor 34,470 29,873 44,829 51,829 50,561 54,030 48,318 56,91,1 65,574 66,456 - 5,211 199,564
I - - - - (3)
Cheboygan Harbor 2.018 9,644 15,027 6.560 12.701 19,115 12.570 14.755 le.t3o 12,905 21,597 16.296 20,822
Detroit 9.692.420 10,442,212 10,408,578 8,041,122 10,120.787 10,291.446 8,992.199 9.819,303 10.9t2.853 12,038,471 12.194,366 11,539,065 10,998,943
- - - - (2,137) - - - - - - (1,500)
Escanaba 238,305 257.612 249,651 253,052 227,863 244.292 262,690 249,766 239,374 313.512 431.923 309,486 288,989
Frankfort Harbor - . 380 18,445 107,713 510 1.006 937 1.735 1.981 205 2,070 1.653 1,232
- (170,381) (138,622) (27,838) (130,811) (103,692) (90,211) (87,220) (77,535) (67,272) (65.093) (32,346) (25,041)
Gladstone Harbor 19,408 16,553 29,165 26,936 28.681 24,041 15,689 36,472 35,210 20,479 31,683 16,722 26.895
Grand Haven
Harbor 67,989 77,616 57,123 66,777 51,717 48,370 83,750 86,418 76,139 65,475 68.572 1.09,244 123,835
Harbor Beach 57.362 54,511. 50,381 45,709 45,028 51,387 37,567 40,513 45,166 31,687 39,566 41,346 8t,063
Holland Harbor 59,643 56,152 76,902 4 6,476 62,674 65,698 85,766 66,536 99.712 67,422 103,291 92,080 70.121
Ud Ludingtun Harbor 98,629 550 123,403 145,806 206,105 192,133 139,904 221,387 179,143 199,400 335.244 196,388 173,615
- (336,302) (264,357) (236,556) (251,376) (219,266) 073,184) (159,433) (155,882) (121.794) (116,832) (125,158) (88,736)
Mackinac Harbor 2.566 3,755 unrep. 2,966 2.594 3.867 2.482 1.741 1,755 1,745 1.725
Manistee Harbor 183,562 215,099 t94.542 174,757 214,671 186,050 208.875 197,607 206,031 221,047 56,658 185.520 221,622
0. 1 - - - - - - - - - - (6,948) - -
Marquette Harbor 192,276 198,958 212,885 178,449 205,795 205,587 248,856 295.321 443,169 394.291 463.390 617,601 604,625
Menominee Harbor 435.177 535,508 467,941 374.776 432,863 474,494 31,1,412 334,792 307,238 223,462 221,896 210.801 196.657
- (288) (7,232) (33,234) (219) (466) . (25) - - - - - (1,232)
Monroe Harbor 19,478 20,926 33,120 19.431 29,618 28,359 1.8,929 27,643 28,522 35,894 31,487 38.390
Muskegon Harbor 749,451 1,182,805 1,337,620 1,1,69,544 I.R8,265 1.190,584 1.091.450 1,142.732 933,755 1,151,812 1,250,101 1.282.700 t.343,377
I - (46,314) (55,555) (46,708) (38,950) (28,280) (21,337) (19,286) (13,401) (9.744) (4,456) (11.909) (2.767)
Ontonogon Harbor - - - - - - - 2.674 - - 11,520 21,737 32.010

Petusky Penn
Dixie Harbor unrep. 155.440 102,394 129.761 139,082 1,52,286 142,808 124.706 145,179 149,605 unrep. unrep. 154.295

Presque late - - - - - - - - - - -
Harbor
Saginaw River 11,649,854 t,538,763 1,573,364 1,267,189 1,829,955 1,874,003 t.930,888 2,108,699 2,320,500 2,524,542 2,984,180 3J70.792 3.165.719
St. Joseph Harbor .28,866 13.119 15,875 11.414 13,099 .4,545 4,507 4,030 3,033 3,335 - - -
Traverse City 50,161. 41,587 47,760 '45,149 43,842 41.690 41,702 46,572 47.331 58,839 50,416 58,350 55,786
I- --A
TOTALS 14,282,324 15,613,342 15,867.710 12,744,148 15,786,328 1.5.863,31.3 14,256,870 16,202.342 16.8 7,651 18,240,766 19.095,155 19,846,974 18.567,688
(553,285) (465,766) (344,336) (423,496) 1 (351,704) (284,757) (265,939) (246.818) (198,610) 1 (193,329) 1 (169,4t3) 1 (119.276 1

RECENT PAST HISTORY OF COAL RECEIPTS AND SHIPMENTS IN
MICHIGAN HARBORS & PORTS (Con't)

PORTS 1968 1969 1970 1911 1912 1973 1974 1975 1976 1977

Alpena Harbur 662,051 668,964 790,596 692,513 633,604 541,679 671,183 594,050 625,062 497.869
calcite 81.943 70,186 75,6o4 68,376 61,572 95,027 t02,O7O 59,599 39,090 11.448
Charlevoix 20a,542 109,99B 149,3112 lib,)15 132,565 141,652 141,596 123,216 113.223 39,936
Cheboygan Harbur - - 14,956 16,136 12,180 8.1to 9,373 - - 18,872
Detroit 10,988,896 9,224,557 9.Ot4.448 7.954,463 217,496 8,162,918 6.570,022 6,859.019 6,800,706 6.275,792
Escanab a 1 240,631 277.946 274,656 166,703 213.613 208,103 231,683 194,095 199.847 154,722
Frankfort Harbor - 345 204 - - - -
(19,585) (7,684) (11,305) (6,641) (3,281) (2,30) (955) (479) (900) (988)
Holland.flarbor 8L,764 107.378 72,910 97,058 84.032 141,345 125,029 103.008 109.324 157,809
Harbor 8each 1 255,728 237,163 316,268 124,380 233,859 201,260 237,402 283,011 296,511 268,318
Gladstone Harbor 17,803 25.505 9,436 9,085 9.375 18.952 - 8,799 21,860 24,160

Grand Haven
Harbor 100J22 98,739 111,489 127,579 78,866 87.839 97,037 82.189 109,00 87,682
Ludington Harbor 180,573 146,334 270,879 79,820 16,448 t6.710 9.690 11,183 34,915 35,159
1. 1 (40,742) (30,823) (19,793) (18.102) (13,268) (8.610 (22,214 (12.499) (3,905) (6.497)
Mackinac Harbor - - - - - - - - -
Manistee Harbor 239,521 247,077 216,243 115,360 145,015 159,604 147.851 154,050 104.779 125,214
Marquette Harbor 639,358 641,625 629,292 524,047 655,587 633.923 909.581 t.096,902 502,055 351.388
Menominee Harbor 149,159 131,080 106.008 73,970 68J71 69,841 49,822 65,477 51.593 83,697
Monroe Harbor 1 24,355 65.973 38,824 20,943 30,t30 37,253 215,438 1,139,816 954.803 1.063.578
Muskegon Harbor 1,596,516 1,416,818 1,642,800 1,806,363 1,429,794 1,898,685 1,919,538 1,503,672 1,736,475 t.553,742
1 (715) (763) (711) (3,327) (319) (207) (146) (1,620) (9,567) KEY
Ontonogon Harbur 26,268 19,419 7,352 - - - - - 9,347 Figure directly opposite
Petoskey Penn port name represents
Dixie Harbor 116.020 137,345 112,543 114,211 127,797 124,058 t23,300 119,872 t08,390 122,404 receipts.
Presque Isle
Harbor - - - - - - - - 581,210 707.475 Bracketed figure
Saginaw River 1,653.181 668,964 1,566,838 1,087.254 646,936 77,401 364,219 62.193 - 158,382 represents shipments.
- - - - - - - - - (26,257) All values represent short
Traverse City tons of coal and lignite.
Harbor 53,523 65,620 72,272 72,832 82,545 65,416 67,336- 46.805 60.141 62.416 1

TOTALS t7.315,960 14,361,036 15,493,060 13,267,808 4,879.645 13,049.4t2 tl,998,170 12,506,835 12,449.001 11,541,678
1 (61,042) (39,210) r (31,809) (28,070) (16,868) (11,135) (23,315) (14.59 5) (14,372) (33,742)

TABLE B-4
RECENT PAST HISTORY OF COAL MOVEMENTS ON HtCHICAN WATERWAYS

WATERWAY 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967

Detroit River 29,679,831 10,442,212 10,408,578 8.033.540 10,122,924 10,291,446 8,975,428 9,819,303 10 910,129 12,089,574 12,204,589 11,513,410 11,006.101
24,173,404 24,283,126 23,301,322 18,951,ago 19,314,441 20,29.9,974 19,444,943 19,778,902 21:609,876 20,358,963 22,177,536 23,385,029 21,652,256

Cray's Reef
Passage 1,600,156 2,000,804 1,811,617 1,103,632 916,084 641,873 565,576 587,319 727,172 998,033 1,020,253 823,476 936,292

1
Keweenaw Waterway 270,969 394,293 358,765 295,847 376,467 374,612 409,257 413,743 486,738 425,655 238,618 285,746 181,180
81,811 48,196 - 33,807 5a,654 9,637 80,590 59,494 10,730 21,426 7a, 719 119,154 110,562

St. Clair River 1,997,795 2,166,7tg 2,194,129 1,739,659 2,566,719 2,325,077 3,025,833 3,450,583 4,097,732 3,941,807 4,341.362 4,455,251 4,481,500
It smrep. imrep. unrep. unrep. unrep. unrep. unrep. 15,776,843 16,852,827 16,628,366 17,030,352 18,815,511 14,311,378
St. Mary's Rivir 715,523 680,191 612,268 486,841 unrep. 485,987 420,296 398,182 406,498 451,551 466,468 523,994 432,631
7,612,926 8,691,833 7,494,057 5,163,537 5,472,496 5,316,037 4,421,570 4,728,465 5,151,499 5,105,666 5,765,343 5,849,017 5,202,674
Ud TOTALS 32,664,118 13,683,414 13,573,740 10,555,887 13,066.170 13,477,122 12.830,814 14,081,811 15,901,097 16,908:587117,251,037 16,778,401 16,101,412
33,468,297 35,oai,959 32,606,996 25,252,260 25,755,675 26,267,251 24,512,679 40,931,023 44,352,104 42,112 4 74 46,066, 203 48,992,187 42,213,162

WATERWAY 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977

Detroit River 10,988,896 9,224,557 9,014,448 7,954,463 8,971,357 8,162,918 6,605,487 6,859,019 6,275,792 6,8oo,706
or 29, 791, 612 18, 306, 547 20,928,412 19,233,422 18,146.643 15,620,234 14,752,260 13,630,872 13,111,112 12,891,683 KEY
Gray's Reef Figure directly opposite
Passage 544,351 736,958 678,329 570,289 622,932 685,985 657,179 734,909 598.129 417,880 waterway represents total
receipts and shipments.
Keeweenaw Waterway 122,43' 55,304 75,179 15,729 47,741 76,874* 77,701 58,803 87,181* 68,483 Figure in italics repre-
56,364 10,785 40,603 31,347 7,569 - 35,635 37,814 - 73,844 sents total movement
through waterway.
St Clair River 4,196,730 4,890,487 4,808,760 4.672,907 4,623,843 3.885,918 3,643,343 2,119,692 1,539,844 1,557,919 Represents total movement
15,668,327 12,227,644 12,604,893 14,138,034 13, 26b, 990 11,603,922 11,590,661 11,677,639 11,594,880 11,405,652 of coal for years where
source did not distinguish
between receipts and ship-
St. Mary's River 489,792 442,109 417,159 301,097 285,205 290,796 254,038 107,266 79,453 28,589 ments and through traffic.
4,155,527 11,051,731 3,723,106 4,877,313 4.969,905 5,994,021 6,554,071 6,737,428 8,009,395 8,205,491

TOTALS 15,797,853 14,612,457 14,315,546 12,944,256 13,154,146 12,339,632 10,580,569 9,144,780 7,895,089 8,455,697
41,216-1181 42,333,665 37,975,343 38,850,405 37,013,039 33,804,162 32,589,806 32,818,662 33,313o516 32,994,550
- - - - - 76,874* - - 87,181*

The following three tables illustrate coal receipts by both rail and
vessel in Michigan's coastal zone. For comparison purposes, these tables
express coal volumes in terms of carloads -- with one carload equalling one
hundred tons. The percentage of total state receipts of each county for each
mode is also indicated .

Table B-5, Port Coal Receipts, represents vessel transported coal
received at Michigan ports in 1975, broken down b'Y counties.

Table B-6, Railroad Coal Shipments, displays the volume of receipts
of coal by rail at various points in Michigan's coastal counties in 1975.
Table B-7 is also included to define the specific routes of coal carrying unit
trains within Michigan.

B-9

TABLE B-5

PORT COAL RECEIPTS
BY COASTAL COUNTY - 1975 (In Carloads)*

COUNTY RECEIPTS PERCENT OF TOTAL

Alcona 0
Alger 0
Allegan 0
Alpena 5940 2.88
Antrim 0
Arenac 0
Baraga 0
Bay 0
Benzie 0
Berrien 0
Charlevoix 1232 0.60
Chippewa 0
Cheboygan 0
Delta 2027 0.98
Emmet 1198 0.58
Grand Traverse 468 0.23
Gogebic 0
Houghton 0
Huron 2830 1.37
losco 0
Keweenaw 0
Leelanau 0
Luce 0
Mackinac 0
Macomb 0
Mason ill 0.05
Marquette 10,969 5.31
Manistee 1540 0.75
Menominee 654 0.32
Monroe 11,398 5.52
Muskegon 15,036 7.28
Oceana 0
Ontonagon 0
Ottawa 83,219 40.32
Presque Isle 595 0.29
Sanilac 0
Saginaw 621 0.30
Schoolcraft 0
St. Clair 0
Tuscola 0
Van Buren 0
Wayne 68,590 33.23

TOTAL 206,424

One carload equals one hundred tons.

SOURCE: Michigan Department of Transportation

B-10

TABLE B-6
RAILROAD COAL SHIPMENTS
BY COASTAL COUNTY - 1975 (In Carloads)

,COUNTY SHIPMENTS PERCENT OF TOTAL

Alcona 0
Alger 0
AT@gan 802 0.571
Alpena 0
Antrim 9 0.006
Arenac 20 0.014
Baraga 0
Bay 19400 13.811
Benzie 0
Berrien 482 0.343
Charlevoix 0
Chippewa 0
Cheboygan 0
Delta 800 0.570
Emmet 92 0.066
Grand Traverse 19 0.014
Gogebic 0
Houghton 0
Huron 271 0.193
Iosco 0
Keweenaw 0
Leelanau 0
Luce 2 OL001
Mackinac 0
Macomb 1750 1.246
Mason 50 .036
Marquette 23100 16.445
Manistee 60 0.043
Menominee 0
Monroe 47450 33.780
Muskegon 57 0.041
Oceana 18 0.013
Ontonogan 2300 1.637
Ottawa 14250 10.145
Prdsque Isle 5 0.004
Sanilac 269 0.192
Saginaw 1502 1.069
Schoolcraft 0
St. Clair 2950 2.100
Tuscola 0
Van Buren 12 0.009
Wayne 24800 17.655

TOTAL 140470

One carload equals one hundred tons.

SOURCE: Michigan Department of Transportation

B-11

TABLE B-7
UNIT COAL TRAIN ROUTES WITHIN MICHIGAN

1. West Olive (Consumers Power, Campbell Plant): 4 Trains/wk.
C & 0 via Toledo, Plymouth, Lansing, Grand Rapids, Holland.

2. Essexville (Consumers Power, Karn & Weadock Plants): 4 Trains/wk
equally split C & 0 and GTW
C&O via Toledo, Plymouth, Flint, Saginaw
GTW via Toledo - D & TShorleline, Detroit, Durand, Saginaw

3. Midland (Dow): 2 Trains/wk.
GTW via Toledo - D & TShoreline, Detroit, Durand, Saginaw, Bay City

4. Lansing (Board of Power & Light): 1 Train/wk.
GTW via Toledo - D &T ShoreLine, Detroit, Durand, Lansing

5. Monroe (Detroit-Edison): 12 Trains/wk
Conrail via Toledo, Monroe

6. Trenton (Detroit-Edison Channel Plant): 4 Trains/wk
D&TSL via Toledo

7. River Rouge (Detroit-Edison): I Train/wk
Conrail via Toledo

8. Connor Creek (Detroit-Edison): Train/wk
Conrail via Toledo

9. Erie (Detroit-Edison): 80 Trains/Yr.
D&TSL via Toledo

SOURCE: Michigan Department of Transportation

B-12

APPENDIX C

RESULTS OF THE COAL FACILITY REVIEW

The results of our coal facility review can be broken down into nine
distinct categories of information. These include:

1. origin data
2. mode data
3. data concerning numbers of individual receipts
4. point of vessel loading data
5. end use data
6. comparisons of industry v. utility use
7. 1979 throughput data
8. throughput capacity data, and
9. projected future changes in coal related activities at these
facilities, including expansion.

ORIGIN OF COAL MOVEMENT

Examination of data gathered pertaining to the initial origin of coal
being received and used in the state of Michigan provides the basis for
several conclusions. First, it is clear that the number of individual
facilities served strictly by coal from the eastern portion of the United
States far out weighs the number of facilities receiving both eastern and
western coal; and no facilities currently receive only western coal. In
contrast to the apparent one sided impression created by this data is the fact
that although the number of facilities receiving coal from the western part of
the country is low, the actual tonnages used by these facilities is often
quite high. Utilities such as Detroit Edison's St. Clair plant ' the Upper
Penninsula Generating Company in Marquette, and the Upper Penninsula 'Power
Company in Houghton, all receive western as well as eastern coal and exhibit
annual throughputs of western coal in the millions of tons.

One possible conclusion drawn from this data could be that even
without a large increase in the number of facilities using western coal,
transportation emands for the eastern movement of the fuel to a few large
users- may increase or at least remain high in terms of tonnages moved. it
should however be noted that the only large western coal using facility
expecting to increase its throughput is Detroit Edison's St. Clair Power Plant.

Another observation which may be pertinent with respect to future
coal facility development within Michigan may be that it is generally the
larger facilities (at least over two million tons annual throughput) which
tend to use both eastern and western coal. In years to come, the construction
on new, large coal fired plants, might be expected to use both types of coal,
and use the west to east transportation system further.

COAL DELIVERY BY MODE

Data concerning the mode of transport of coal to various utilities
and industries in the Michigan coastal zone shows that the great majority of
coal delivery in this portion of the state occurs by way of lake vessel.

C-1

Sixty-seven percent (67%) of all coastal zone facilities using coal rely
exclusively on waterborne transport, 14% employ only rail, and 19% use a
rail/water mix to obtain their fuel.

By breaking the state of Michi.gan down into Coastal Regional Planning
Areas (see Figure), and examining the transport mode data with respect to
these sub-state regions, several observations can be made. ' Perhaps most
apparent is the basic difference in the utilization of rail and lake vessels
as transport modes between coastal regions located in the southern two-thirds
of the lower penninsula and the rest of the state. The results of the study
show that while facilities in the southern half of the state of ten received
coal by rail as well as water, utilities and industries in the nine northern
regions rely exclusively on vessel transport for the receipt of coal supplies.

FUTURE EFFECTS

These observations can clearly be of some use when trying to
determine areas which would be most likely to be impacted by coal
transportation in certain ways. For example, one conclusion may be that
impacts associated with the transport of coal by rail, such as community
interference, noise, and fugitive dust, are not currently important
consid.erations in the state's northern regions with respect to coal
transportat ion . Fo 1 lowing the same log ic , one could al so assume that reg ions
in the southern half of the state may be subjected to a wider range of
transport related effects, and therefore could require mitigation measures for
dealing with incremental effects of both increased rail and vessel coal
movement.

Further insight regarding transportation impacts can be gathered by
combining the mode data with information concerning the number of actual
vessel and train receipts by facilities in the various regions and their
points of origin. An examination of this type provides not only an indication
of where trains and vessels transport coal to in Michigan, but also from where
and how often.

COAL RECEIVING

The results of the study concerning individual receipts and their
origin continue to support the conclusion that southern Michigan is the most
heavily taxed by coal transportation impacts. Though it is the northern
regions which rely exclusively on vessel transport for the receipt of coal,
regions in the southern half of the state on the whole do receive more
individual vessel shipments in a given year. The fact that rail receipts are
restricted to facilities in the southern regions of course indicates that any
rail related effects now occurring may increase in extent or magnitude with an
increase in coal use, data shows over one thousand individual train shipments
to regions 1, 7, and 14.

VESSEL LOADING

Though information regarding the specific point of train loading
prior to facility receipt was often hard to obtain, geographic conditions make
it clear that any coal transporting trains must pass through some part of
southern Michigan in route to any facility in the state, providing the

C-2

potential for adverse impacts in these regions should coal transportation
increase. Similarly, approximately 80% of all vessel receipts by Michigan
facilities originate at Lake Erie ports and must either use harbors in
southeastern Michigan or pass through connecting channels in these regions in
the transport of coal. Potential vessel impacts such as shore erosion could
therefore be expected to be concentrated in and around southern ports and in
channels such as the Detroit River and the St. Clair River.

END USE OF COAL

Data collected concerning the end use of coal in Michigan clearly
shows that the great majority of all coal receiving facilities in the state
use their coal in power generation. Consequently, annual receipts of coal by
Michigan utilities is six times that of Michigan industries.

Further examinatipn of actual facility tonnage throughput by region
shows that receipts are especially concentrated in certain parts of the state.
The three primary regions using coal for utility purposes consume about 65%
of all coal received in the coastal zone, while the three regions using the
most coal for industrial purposes other than power generation use about 13%.
In total, almost 80% of all "coastal coal" is used in four specific areas
within the ten coastal areas used for discussion purposes, and this fact again
contains implications for the identification of areas of possible
environmental impacts within Michigan. Table further defines these regions.

CURRENT FACILITY USE AND FUTURE EXPANSION

The last area examined concerned the possibility of coal facility
expansion or tonnage throughput increases. Two questions were important here.
First, does the facility have the capability to expand its plant or increase
its throughput, and second, do they intend to or plan to increase their
throughput or expand their facility in the future.

A study of current throughput capacity among those coastal facilities
responding showed that about 85% of these facilities are currently operating
at below capacity. When their current versus indicated maximum throughputs
are compared, the current throughput of these facilities is about 40% of what
they indicate they are capable of handling. About 70% of facilities
responding indicated they are capable of expanding their facilities if needed.
Those two facts would tend to support the conclusion that Michigan's coastal
coal unloading facilities could conceivably handle at least a doubling in
coming years if the demand for commodities such as power increased or other
factors made it desirable.

In contrast to the above indications of increased coal use in
Michigan's coastal zone were the responses to inquiries concerning expected
throughput increases. Only 36% of the facilities contacted expect to increase
their annual use of coal, while almost 42% expect to remain at or near current
levels and almost 14% anticipate tonnage throughput decreases. Actual
increases in coal movement through the Michigan coastal zone may not therefore
increase at the rate at which they are capable of increasing in the coming
years.

C-3

TABLE C-1
ORIGIN DATA

Regional Origin

Eastern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89.5%
Western . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0
Both . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10.5%

Tonnage

� Receipts by facilities receiving only eastern coal 10,600,148
� Receipts by facilities receiving both eastern and
western coal 10,948,518

Facility Expansion

� Total number of facilities indicating expected tonnage
increases 14

� Of these:
92.9% currently use only eastern coal
7.1% currently use eastern/western mix

TABLE C-2
MODE DATA

* 66.7% of all facilities in coastal zone receive coal only by lake vessel

* 14.3% of all facilities in coastal zone receive coal only by rail

* 19.0% of all facilities in coastal zone receive coal by both vessel and rail

* Of Facilities receiving coal exclusively by vessel
10.7% are utilities
89.3% are industries

* Of facilities receiving coal exclusively by rail
100% are industries

* Of facilities employing both modes
100% are utilities

c-4

Region I Region 10
Vessel 31.3% Vessel 100%
Rail 31.3%
Both 37.4% Region 11
Vessel 100%
Region 7
Vessel 40% Region 12
Rail 40% Vessel 100%
Both 20%
Region 13
Region 9 Vessel 100%
Vessel 100%
Region 14
Vessel 75%
Rail 25%

TABLE C-3
POINT OF VESSEL LOADING BOUND FOR MICHIGAN

Toledo 38.2%
Sandusky 21.8%
Conneaut 16.4%
Chicago 7.3%
Superior 7.3%
Ashtabula 5.4%
Other Great Lakes Ports 3.6%

TABLE C-4
USE DATA

Power Generation 59.5%
Manufacturing 16.7%
Heat (Space Heat) 11.9%
Steam (Industrial) 9.5%
Vessel Fueling 2.4%

OFF SITE USE

Coal is moved offsite for use after initial unloading about 13.5% of
the time and used, at or near the point of unloading about 86.5% of
the time.

C-5

TABLE c-5
NUMBER OF INDIVIDUAL COAL RECEIPTS

REGION VESSEL RAIL

Region I
Utilities 354 680
Industry 9 0
Total 363 680

Region 7
Utilities 39 225
Industry 2 53
Total 41 278

Region 9
Utilities 0 0
Industry 54 0
Total 54 0

Region 10
Ut ir-it ies 18 0
Industry 30 0
Total 48 0

Region 11
Utilities 0 0
Industry 8 0
Total 8 0

Region 12
Utilities 109 0
Industry 113 0
Total 222 0

Regio@ 13
Utilities unreported 0
Industry 0 0
(represents one utility, 2,275,149 ton annual throughput)

Region 14
Utilities 81 150
Industry 1 0
Total 82 150

TOTALS
UTILITIES 601 1055
INDUSTRIES 217 53
TOTAL 818 1108

C-6

TABLE C-6
1979 THROUGHPUT

Utilities Industry
Region (tons) (tons)

Region 1 8,740,000 302,000
Region 7 2,175,000 15,000
Region 9 --- 87,000
Region 10 130,000 263,406
Region 11 --- 150,000
Region 12 2,940,000 2,303,111
Region 13 2,275,149 ---
Region 14 3,090,000 11,000

TOTAL 19,350,149 3,305,517
COMBINED TOTAL 22,480,666

TABLE C-7
THROUGHPUT CAPACITY DATA
(20 responses)

Of these 18, or 84.6%, indicated that their current throughput is below
capacity.

Amount of Capacity Utilized
Current Maximum

8,000 100,000
0 200,000
11,000 800,000
72,406 124,000
140,000 250,000
0 150,000
2,073,369 10,000,000
36,000 90,000
11,000 2,000,000
377,000 1,705,000
3,800,000 4,400,000
80,000 800,000
2,600,000 3,000,000
526,000 680,000
332,000 640,000
175,000 320,000

TOTAL 10,241,775 25,259,000

APPROXIMATELY 40.5% OF CAPACITY

C-7

TABLE C-8
REGIONS OF GREATEST COAL USE

Top utility regions and some major use points

Region I Region 12 Region 14
Detroit Marquette Grant Haven
Monroe Gladstone Muskegon
Wyandotte West Olive
Erie

Top indusLrial regions and some major use points

Region 1 Region 10 Region_12
Monroe Manistee Marquette
Marine City Petoskey Munising
Detroit Charlevoix Gladstone
Escanaba
Menom inee

TABLE C-9
PROJECTED TONNAGE CHANGES
(36 responsM

Expect to increase throughput 36.1%
Expect to decrease throughput 13.8%
ExpecL to remain stable 41.6%
Uncertain 8.3%

Percentage of Facilities Indicating Expected Increase by Region

Region 1 20 %
Region 7 50 %
Region 9 0 %
Region 10 40 %
Region 12 37.5%
Region 13 0 %
Region 14 75 %

Expansion Capabilities
(Facilities Answering Yes or No)

27 responses Yes 70% No 30%

C-8

TABLE C-10
MICHIGAN FACILITY REVIEW

- ---------- ----
FINAL NO. OF 1979 TURDUGHPUr STORAGE PROJEcreo PossiBiLiTy
ORIGIN OF TRANSPORT POINT OF DESrINATION RECEIPTS THROIJUIPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANCES.
ORGANIZATION RECEIPTS ____ MODE - LOADING AND USE PER YEAR (TONS) - (TONS) (TONS) TONNAGE EXPANSION SPECIAL PROBLEMS, NOTES

REGION I
Ind.SLry
KoeriLl Fuel & Supp Information not forthcoming
De-LroiL , ML

Fo?d motor@
Metcd Stanping Dioision
Kn1rue, MI I Eastern Lake Toledo, OR Monroe, MI; 3 36,000 to None Yes
vessel SLemu 40,000 expected
McClouth Marine YardB Could expand to maximum through-
Mariu@ City, EasLera Lake Toledo, Oil Marysville 1 8,000 100,000/yr 15,000 Yes put, but would have to eliminate
Mi KY, W.VA, (it Vessel (16 mi. by (see note) stone cargoes.
I truck)
De t ioi t Lime Co.
Wtr,,iL, MI EdSLOrll Lake Toledo, Oil Detroit; Heat 4-5 <10,000 40,000 98,400/yr Yes
KY Vessel as of 1981
<1% buLfur

American Ho
Detroit, Mi I KY Rail 6,000
Great Lakes Steel
1@10 Detroit, MI E-t-- Lake Toledo, Oil Z.& Island, 150 Vessel 2,631,365 None Yes
Ve.s.1 90% Mi loads expected
Rail 10%

Marbleh-ad L u*na Co. *
Riv@r Rouge, JKY, W.VA, Rail 100,0oo
mi EasteruVA

Ditwopici Crjj it Salt Co.*
Detroit, Mj Rail 140,000
litility
Coneit"el's
Erie, Mi Eastern Rail Eric, MI; 80-130 800,000 180 day
KY, IL, OH Detruit & Power supply
W.VA To 1 edo Generation
<1% sulfur Shoreline
Ptoute
Detypit Pid) Lightirg No longer have coal burning units,
tors C0!'P-

[SI-81

Detroit, Mi all oil. Receiving no coal & have
no plans to receive coal in future.
Kzpn&tte M :ciWl Service Corrmfrsian Have tried to get a 150' extension
Wyandotte, MI Eastern Lake roledo, OH Wyandotte, Mi 5-7 60,000 to 45,OOU None at No onto storage area but so far the
KY Vessel Power 70,000 this time request has been denied.
<0.75% sulfur Generation

-ZTY -s' "j-': I I I --- I --- I I -- I
-- --I Us Zu-al -, ---

MICHIGAN FACILITY REVIEW (Cont.)

MAX IM UM MAXIMUM
FINAL NO. OF 1979 THROUGHPUT STORAGE PROJECI-ED POSSIBILITY
ORIGiN OF TRANSPOKf Poiar uF DEsTiNxrm RECEIPTS THROUC31PUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANGES,
ORGANIZATION RECEIPTS _____R)DE ... LOADING ____ AND USE PER YEAR (TONS) (TONS) __ (TONS) TONNAGE 1EXPANSION SPECIAL PRUBLEMS, NOTES
oety,oit Edison
Tr.lftoa, MI Appalachiao 25% Vessel- Ship capacity is currently
Power V-s-,21-31 Es r imaLed 1,705,000 5ob'000 No increase Yes, additional fully utilized.
Coal ( low Ves'el Sandusky, Off Generation Rail-150 1980 expecred mobile equipment
sulfur) 75X Rai i Rail-Eadtcra 377,000 could increase
I origin throughp.t
Detroit Edison
Ship unloading capacity is
St. Clair, MI Western Coal 98% Vessel- Power Vessel 58 E&Limated 4 million 3.1 Up to 4 Not needed restrained by the capacity of
V.sse I Superior, WI; Ceneration Rai I- [lot 1980 3.8 million million a central hopper.
2% Rail Ashtabula, available million
Toledo, Oil
Rail-EaSLero
.rigin

Detwit Edison
Ship unloading capacity is re-
River liouge, Appalachian 6%-Vessel Vessel- Power Vessel-8 Estimated 800,000 500,000 No increase KA needed strained by the capacity of a
Mi Coal ( low 94%-RaiL Toledo, GeneraL ion Ra i 1- 138 1980 expected central hopper.
.ulf.r) Sandusky, Off 80,000
Rail-Eastern
origin

Det?,oit Adison
1980 was estimated as the peak
penn.al L Appa L achiaii 100Z To I edo Power 8 Es L ituaLed 70,000 No increase Not needed year for the dock. Ship capacity
Goa I ( low Vessel Generation 1980 expected is currently fully utilized.
sulfur) 160,000
Detroit Ediso I
Ship capacity is currently fully
0 Monroe, Ml Appalachian 41% Vessel- Power Vdssel-176 Estimated 3 million 2.3 Uncertain Yes, additional utilized.
Coat (low & vessel Ashtabula, Generation Rail-287 1980 mi I t ion mobile equipment
high sulfur) 59% Rail Toledo, 2.6 million could increase
Sandusky, (It; throughput
Rail-Eastern
origin
Deti,oit Edis"',
Ship unloading capacity fully
Marysville Appalachian 97% Vessel- Power Vessel-39 Estimated 680,000 191,000 625,000 Yes, additional utilized.
Mi Coa I ( low Vessel Toledo, Generation Rai I- not 1980 tons for mobile eq.ipmunt
sulfur) 3% Rail Sandusky, 011; available 526,000 1981, could increase
Rail-Eastern increasingly throughput
lower volcmes
after

Detrvit Ediaort
20,000 tons per year is trucked
G)nnors Creek Appalachian 77% Vessel- Power Vesdet-28 Estimated 640,000 260,000 No increase s, additional off-site. Ship unloading capacity
Ml Coal (low Vessel Sandusky, Generat Lou Rai I-not 1980 expected bile equipment fully utilized.
sulfur)
23% Rail Toledo@ 011; HeaL available 332,000 could increase
Rail-Eastern throughput
origio

Detroit Edia')n

China Town- NT Lake Duluth- Power None 4,000,000
ship, M1 Vessel Superior GeneraLion - 1984

Industry Manual.
T

MICHIGAN FACILITY REVIEW (Cont.)

MAXIMUM MAXIMUM
FINAL NO. OF 1979 111ROUGHPUT SIDRACE PROJECTED POSSIBILITY
ORIGIN OF TRANSPORT POINT OF DESTINATION RECEIPTS THROUGHPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANGES,
ORGANIZATION RECEIPTS WDE LOADING AND USE PER YEAR (TONS) (TONS) (TONS) TONNAGE EXPANSION SPECIAL PROBLEMS, NOTES

REGION 7
industry
Hercules Pooder Co. The need for coal has been small.
Harbor Beach, EaStern Rail Harbor Beach 1 4,000 Wne Yes The boilers are Loo big for their
Mi KY, VA, W.VA Power (See uoLeS) purposes, therefore they are
GeneraL ion switching over to natural gas. It
is possible to expand the facilities
but there is no need. only one
boiler will remain on standby
for coal. If they increased coal
movement they would have to expand
the plant and dredge the harbor
Wirt Stone Dock which is currently 10-11 feet deep.
Bay CiLy, MI @Eastern Lake roledo, Oil Michigan Sugal 2 Naae 200,000/yr Uncertain Yes
KY V'assel W. (10 mi. by
LrLbzk); SL,am
C
,eneration

Chevrolet @naj Grey rnon Fouwry
Saginaw, MI Eascorn pail Sag inaw; OLICe/wk. 11,000 100 tons/hr. some expected No
KY Cliessie KR Steall frcm Oct . but nouhere I
Generation t. Apr. 1, near capacity
3-4 cars
C load

F" Wirt Sagiww Stone Vock
FJ No longer receiving any coal.
Saginaw, MI I
Robert Gage ,ady M No longer receiving any coal.
Bay CiLy, MI

ULiliLy - i I
Cortsuriers Fbidee Co.
"suxvitl.' Easr@ra Lake Chicago, IL Essexville 10-30 by 300,000 180 days No
mi KY, IL, Cil Vessel & T@Iedo, Powe r vessel by Lake supply
W.VA Ra i I Swidusky, Oil GeneraLiun 170-280 vessel
<1% sulfur by train 1,700,000
by Rail
(C & 0)

Detroit Edism
Harbor Beach, Appalachian 100% ToLedu, Power 19 EstimaLed 320,000 165,000 Up to Yes, additional
mi Coal (1,ow vessel Ashtabula, GeneraLion 1980 245,000 mobile equipment
sulfur) Sandusky, Oil 175,000 Lons could increase
throughpuL

REGION 8

Paj Chemical All boilers have been converted to
LudingUllk, MI oil. There are no plans to convert
back to coal.

VeySLOW Coal liduSLry Maiiual.

MICHIGAN FACILITY REVIEW (Cont.)

----------
MAXIMUM MAXIAUM
FINAL NO. OF 1979 THROUGHPUT STORAGE PRojEcTED POSSIBILITY
ORIGIN OF i,RANsioxr POINT OF DESTINATION RECEIPTS THROUGHPUT CAPACL'ry CAPACITY FUTURE FOR FAciLiTY CATEGORIES OF CHANCES,
ORGANIZATION RECEIPTS MA)E __ LOAD ING AND USE --PER YEAR (TONS) (TONS) (TONS) TONNAGE __ EXPANSION SPECIAL PROBMLEMS, NOTES

REGION 9
Ind-try
fluvon Cment VtviBion
Alpena, MI EaSL,r.1 Lak, Saod.sky, Cement 40-50 450,000 No increase Storage pile
vessel Conneaut, Oil MaiiufacLuring expcLed could be
expanded
A 1,itibi co

Alj@na, Mf Eastern Lake Toledo, OH Pwer Gener- 9 75,000- No increase
Vessel ation, H@at 85,000 expected
michigarl Lifliealoru-,
P4191178 City, MI Lake Heating & 7,000 Currently Will probably
Vessel fueling of decreasing contact
I vessels
CEPS Afar6te Tefair"I
Ctwb@ygau, Eastern Lake Cleveland, 1/2 mile 1 3o'OOO None No
MI KY Vess'l )11 inlaud; Expected
process heaL

REGION 10
Industry
flartly Salt Co. No longer receiving any coal.
f MallibLee, Mi
Morton Salt V ivision 1979 tonnage figure may not be
Manistee, MI EasLerll Lake roted., Oil Power & sLealn 6 50,000 'urreat is 10% increase representative due to a strike.
KY vessel beating of ot max. over next 5 Expect an increase in movement,
buildings yrs unknown but no facility changes anticipated
after that
Perok-Vixie Cement
In 1978 they received 123,497
P.Lobky, M1 I EdIL.rn Lake 3onueauL, Oil NanufacLuriog 10-12 72,406 124,000 M) increase No, too tuns. The sharp 1979 drop was the
Vessel expected costly result of production variations.

Medusa Cement Co.
There is no current need to expand
Charleviiix, Eastern Lake iaudusky, Used to 10-15 140,000 250,000 Waut to Possibly facilities. They have recently
NI Vessel Uonaeaut, oil nanufacture decrease (see notes) modernized In order to use less
I Cliflent. conswilt ion coal.
Northevn igun Electric Corp. COE have plans to deepen and
M-'Y'l. Ci I Y, KY La ke iai,d.sky, Oil Power 13-15 106,000 Expect No, Permits straighten the channel at
MI S. 11. vessel hicago, IL C--nerat.ioll Decrease to -24 pand Charlevoix, but they have been
(I unit dowu@ are [lot postponed. The channel work may
likely to be be a factor as to whether they get
granted coal at all. Need access to bigger
newer ships.

MICHIGAN FACILITY REVIEW (Cont.)

MMA"M MAXIMUM
FINAL NO. OF 1979 THROUGHPUT STORAGE PROJECTED POSSIBILITY
ORIGIN OF TRANSPOKI' POINT OF DESTINATION RECEIPTS THROUGHPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF GRANGES,
ORGANIZATION RECEIPTS H)DE __ LOADM AND USE PER YEAR (TONS) (TONS) (TONS) TONNAGE EXPANSION SPECIAL PROBMLEMS. NOTES

REGION 10
Utility
Triaverse City Light & Pcwep
Beyond 1993, no plans to expand
Traverse KY Lake Toledo, Oil Power 2-5 24,000 20,000 1981-1993 Towivship is coal facilities. Probably will
City, MI Vessel & Lake Erie Generation 60,000/yr opposed to purchase power from other
Ports ex pans ion utilities after that. Dredging will
be required to handle existing
needs due to low water problems
REGION 11 near dock.
Industry
0. Reiss Coal Co. Indicate possible use of excess
Sault SLe. EasLerL1 Lake Toledo, OH Power, HeaL 7-8 &'at. >150,000/yi- Expect Current capacity.
Maire, MI Vessel used by increase in facility still
Abitibi Curp in 1980 underuLilized
& St. Prison

REGION 12
1 ndus a ry
L3 & I Railrvcd This facility differs from a
Marq,iette, Eastern Lake Superior, WI Power ]Do 2,073,369 10 million I million Yes loading dock or transshipment
ill Lower GL's Vessel & Lower Great Generation tons facility in that coal does not come
Western W Lake Ports for utilities here directly from the mine and
n & mining ccop- has already been "transshiped."
anies. moved to
these destina@
tions by Wait
trains.

Mwdsin3 Paper Div.
MLilliSilkg, MI JW.PA Lake Paper 3 35,775 Current No increase
Eastern KY Vessel Manufacturing expected
Del ta Cwt S Dock
This facility differs from a loading
Gladstone, MI PA Lake @utineaui:, Oil Paper 3-5 36,000 80-100,000 Anticipate Yes, approx. dock or transshipment facility in
vessel mills increase 70 acres of that coal dues not come here
land available. directly from the mine and has
already been "transshiped". It
differs from the other industries
in that no coal is used on-site.

C. Reiss Coal Co.
This facility differs from a loading
Escanaba, MI KY, Oil, Lake Poledo, Oil Moved offsite , 91,967 Depends oat 1980 - dock or transshipment facility in
W. VA, PA Vessel in a radius of tonnages 50,000 toll that coal does not come here
about 80 miles stored for increase directly from the mine and has
by truck later ship- already been "transshipped". It
talent differs from the other industries
in that no coal is used on-site.

Keystone _rZT.-IF
ndustry Mausi.

MICHIGAN FACILITY REVIEH_jLont_.)
MAXIMUM MAXIMUM
FINAL. NO. OF 1979 THROUGHPUT STORAGE PROJECTED POSSIBILITY
ORIGIN OF TRANSPORI' POINI' OF DESTINATION RECEIPTS THROUGHPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANCES,
ORGANIZATION RECEIPTS-- MODE I.OADING AND USE ---. PER YEAR (TONS) - (TONS) (TUNS) TONNAGE EXPANSION SPECIAL PROBUEMS, NOTES
Matuninee Paper Co.
Men,nineo, PA, S.IL, Lake Paper 6 66,000 AbuuL No increase Yes
MI <1.5% sulfur Vessel ManufacLurinE current expected at
tonnage this time
ALarquette Board of L ** t & ower Must dredge channel annually to
Marque.Lte, MI Western Lake Conneaut ON Power 6-7 128,000 75,000 After 1982 Currently maintain 20 ft. depth. Usually in
PA Vessel Generation expect to adding new the spring. Also will have to
<1 .5% sill fur use 250,000 unit, will be Install a conveyor belt to handle
coote'lt -300,000 oil t ime by anticipated coal increases.
tons/yr due 1982
to the addi2
tion of a
new unit.
Gladstone Light Utility Air emissions tests are currently
GI.IsLone, MIjW.PA Iake WavailL, OH Power 1-2 12,000 60,000 Unkripwit yes being conducted on two units. One
<1.5% sulfur Vessel Generat ion has passed. If the other does not
COnteoL pass the plant will be closed down.

Upper Peni 'a Genemtinq Co.
Marquette, MI W.MT, WY, Lake Superior, W1 Power 99 2,800,000 No increase
W.VA, VA, Vessel s Toledo, Generation Usually expected
KY Sandusky, try for
WnueauL, CH 100/yr

F1
REGION 13
Utility
Upper Peninsula Power Co. No foreseeable growth in future.
HoughLou, MI 1. PA Lake Eastern: 1. Escanaba 2,275,149 1. 75,000ISame as Not at
2. PA Vessel Sandusky 2. Houghton 2. 100,000 1979 Marquette
3. PA, W.VA, Toledo 3. Marquette 1. 58,207
VA, KY, LIT Conneaut, Oil Power 2. 84,538
Western: GLneraLiun 3. Eastern
Superior, WI 902,404
Western
1,230,000

RLGION 14
Indu,,Iry
Verplank 'a coal & Dock co. This facility differs from a loading
Ferrysburg, S. IL 1,ake Chicago, 11 Rockford, MI 1 11,000 2,000,000 1981 - Yes dock or transshipm-ent facility in
MI vessel Paper 24,000 that coal does not come here
Manufacturing tons directly from the mine and.has
already been "transshiped". It
differs from the other industries
in that no coal is used on-site.
S.D. War-ren Co.
No longer receives coal.
Muskegon, MI

Keyst ... te Coa--T-Au1L1;--N-l--r---

MICHIGAN FACILITY REVIEW (Cont.)

MAXIMUM MAXIMUM
FINAL. NO. OF 1979 THROUGHPUT STORAGE PROJECTED POSSIBILITY
ORIGIN OF TRANSPORr POINT OF DEsnNAIAON waivrs rnouamrr CAPACITY CAPACITY FUl1JRE FOR FACILM CATEGORIES OF CHANCES,
ORGANIZATION RECEIPTS MODE LOADING AND USE PER YEAR (TONS) (TONS) (TONS) TONNAGE EKPANSION SPECIAL -PROBLEMS, NOTES

Utility
Grund Haven Hoard of Light & Power 1983 unit will burn higher sulfur
Grand Havtal, KY Lake Conneaut , Oil Power 5-6 90,000 50,000 tk)vr-1983 No, Loo coal. Coal will probably come from
MI Vessel Ceneration 75'a0O - costly Indiana. The unit.will include a
90,000 tolls/ scrubber.
yr After 1983
about 150,000
Lons/yr due
to new unit

Conszjrner@s POWLP
Mu.k.gon, MI KY, IL, OH Lake Chicag", IL Po@-r 75 1,50U,000 180 days 1983 - No
W.VA Vessel Toledo, OH G-leCaLiull supply 1,500,000
will probably
be disLribuLed
to otll@r plants
also.

Consi,mers Power,
We@L OLive, KY, It, Oil Rail Powr more Lhan 1,500,000 180 days 1,500,000 lb
Ml W.VA Generation 150 supply increase
in 1980 by
unit train.

F1
Ln

COAL TRANSSHIPMENT FACILITIES

The feasibility of establishing a coal transshipment facility at
Escanaba is being examined at the University of Michigan. At this time, it is
not clear that such a facility is economically feasible nor what companies
would use the facility. The reasons for proposing such a facility to avoid
the Sault Ste. Marie Locks in winLer because of ice cover and potential
capacity limits at the Locks and provide for the possibility of using large
vessels on the Lakes Michigan, Huron, and Erie to transport western coal to
large coal users located on those lakes. No other information concerning this
facility is available at this time.

GREAT LAKES STATES

A revIew of current coal using facilities in the Great Lakes States
other than Michigan was also conducted in an attempt to gain a better
understanding of regional coal movement and facility development. The
information gathered is presented in two tables. Table B-1 presents data for
coal using industries and utilities and Table B-2 displays information
gathered regarding coal transshipment facilities within the coastal zones of
Great Lakes states other than Michigan.

C-16

TABLE C-11

OTHER LAKE STATE FACILITY REVIEW

FINAL M). OF 1979 nimucUpur STORAGE PROJECI*ED POSSIBILITY
ORIGIN OF ARANSPOKC POIMV OF DESTINATION RECEIPTS THROUGHPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANGES,
ORGANUZATION RECEIPTS @UDE LOADING AND USE PER YEAR (TONS) (TONS) (TONS) TONNAGE EXPANSION SPECIAL PROBLEMS, NOTES

LAKE STATES

MINNESMA
Industry

0 Heist; Coal Co. Variuus 213,800 800,000 5% +/yr. This facility differs from a load-
Duluth, MN locations & increase ing dock or transshipment facility
uses by moved in that coal does not come here
within a 100 directly from the mine and has
mile radius by already been "transshipped". it
truck & rail differs from the other industries
in that no coal is used on-site.

H@usep!@uMining astern Lake 3-4 50,000 300,000 No need. 1978-100,000 tons. Annual tonnage
Co. W.VA, E KY Vessel Want to reduc depends on availability Of other
TiTiver Bay,MN Z sul fur SLockpi I ing. fossil fuels and amount stock-
piled. Government regulations
are the major factors forcing
coal conversion. This industry
would prefer to continue using
natural gas.
ErLe Mintny Eastern lAke Toledo, Schroeder; 30 600,000 Current None No
Q.9% surfur Vessel Conneaut , OH Steam tonnage expected
Taconite generation
Harbor, MN

WISCONSIN
Industry

C. Heist; Coal Eastern Lake Tuledo, Various 266,000 300,000* None at Yes A second dock facility can accommo-
CO. Vessel Conneaut, OH locations, this time, (see notes) date 200,000 tons more throughput.
@_.h I and ,Wi shipped Out but hopeful Constraints on coal receipts
by rail & about futur@ Imposed by winter-ice breaking is
truck (85% required, poor rail service, &
rail) unreliable gov't. dredging of
channel. This facility differs
from a loading dock or transship-
ment facility in that coal does
not come here directly from the
mine and has already been "trans-
shipped". It differs from the
other industries in that no coal
is used on-site.
For,t flota@rd Eastern Various 518,800 700,000 5% +/Yr. This facility differs from a load-
Paper Co. locations & increase ing dock or transshipment facility
Green Bay, WI uses. Usually in that coal does not come here
coal is moved directly from the mine and has
within a 100 Iready been "transshipped". it
aile radius by differs from the other industries
truck or rail in that no coal is used on-site.

It lz@y_st`one -Coal- -Ind o-str_y__M_a-nuaI .

OTHER LAKE STATE FACILITY REVIEW (Cont.)

- ----------- - ----- - -- ---- - ---------- - -- -----
MAXIMUM MAX INUM
FINAL NO. OF 1979 THRowipur STORAGE PROJECTED POSSIBILITY
ORIGIN OF TRANSPORT POINT OF DESTINATION RECEIPTS THROUGHPUT CAPACITY CAPACITY FUTURE FOR FACILITY CATEGORIES OF CHANCES,
ORGANIZATION RECEIPTS MDDE LOADING AND USE PER YEAR (TONS) (TONS) (TONS) TONNAGE- EXPANSION __ _SPECIAL PROBLEMS, NOTES
C. HeiSS Coal Eastern 62,000 175,000 5% +/Yr. This facility differs from load-
CO. increase Ing dock or transshipment facility
Ya-niLuwoC, W1 in that coal does not come here
e.irectly from the mine and has
already been "transshipped." It
eiffers from the aLher Industries
in that no coal is used on-site.

A1114M,tte Eastern Lak@ Toledo, Oll Indust ry & Variable Still sing 125,WO 13 acres sume Yes, but Expressed need for increased
FueT j -7kx,,k KY, W.VA Vessel S. Chicago, 11 residences; coal from eXpeCLed, market eredging. Channel has not been
Co. Heating 1977 ship- but not in conditions dredged for eleven years and this
Marinette, WL (movcd 50-60 ment: xcess of do not could be a problem If more coal
mi. by truck) 75,000 Lons require it. Is moved.

11c"Ietail, 1w Eastern Lake Milwaukee; 240,000 C.rrent. None Yes Amount of coal used is directly
Milwaukee, WI W.VA, vessel used to make Expected connected to demand for the pro-
approx. 4% coke duct; they cannot make coke with-
siA for content out coal.

Schneider Fue VA &.1il & Private homes 15-20 1000-1500 100-120 Yes, but Shipments of coal leave this facil-
" S 'y . TY,ck hone heaLing io need to ity nearly every day during the
11`12ukee@owl winter & less often during warmer
rionths, by truck.
Milwukve Eastern Lake Making coke 240,000 Current es
00 Solvay V@ssel
CoU Co.
MjT-w-a-ulwe, WI

ULiliLy__

W Publ ic Eastern Lake 60 935,000 1,200,000 Expect on In the Working with Green Bay Harbor
Service Coran. W. PA, W. KY vessel increase planning Commission on future harbor devel-
Green Bay, WI average are in Lhe sLages opment and the possibility of
sulfur process of fULure transshipment at the site.
cOnLent 2.5% planning
facility
im P:ove nL
& . p.,:ei.n
W1 EleCtr-ic East ern Lake Ashtabula Port 50-70 700,000 No firm F I es Draft restrictions i4inge on
Powr Co. E. PA & (At V"sel )r Washington, limit increase, but vessel size.
T;r--tWasf1 i ng- Wnneaut. , Oil Power no numbers
ion, Wl Generat ion available

Ic
a nd.tstry Kmoal..

OTHER LAKE STATE FACILITY REVIEW (Cont.)

MAXI?4UM MAXIMM
FINAL No. OF 1979 TILROUGHPUI' STORAGE PROJECTED K)SSIBILITY
ORIGIN OF TRANSPOW PoiNT OF DESTINAXION RECEIPTS THROUCHPUT CAPACITY WACITY FUTURE FOR FACILITY CATEGORIES OF CHANGES,
ORGANIZATION RECFIPTS ___K)DE __LOADING, AND USE PER YEAR (TONS) (TONS) ___ (TONS) -TONNAGE EXPANSION __5 F PROBLEMS, NOTES

k2 p
@ I ccty@tc Eastern Rail Oak Greek; 260 2.5 No firm 1,300,000 Expect an Yes Unusually low tonnage for this
PoLvr Co. IL & KY Power millicio* limit increase, but plant 1978 tonnage was 3.2 million
Oak Cree , WI Wesuern Generation "o numbers
. WY
W1 Electric Eastern Lake Ashtabula Milwaukee 66 660,000 No firm Expect an lQuesLionable Draft restrictions impinge on
Poza?r Co. PA, (*I, IL vessel or Cbnn@811L Power limit increase, but vessel size.
gi-lwa.kee, WI W.KY Generation no limbers
livailable

NEW YORK
UL

N iagara- Eastern Lake WnneauL & Power 20 by 150,000 Wile Yes
MohaWk Pcxxr PA & KY Vessel 10, AshLabula Electric vessel by vessel Expected
Co. Rail 75% Ohio Generation 4 trains 1.25 millior
7i@,_nawanda, Truck 15% per week by rail
NY 360,000 by
truck

I@e_Ystone joal Industry Kartual.

APPENDIX D

MICHIGAN POWER PLANTS

4
This appendix lists power plants in Michigan by operator, location,
status, years in operation, fuel, size, cooling system, and cooling water
source.

D-1

TABLE D-1
MICHIGAN POWER PLANTSa
(OPR & STN)b
OPERATOR CITY PLANT NAME STATUS YEAR FUEL MEGAWATTS COOLING --@-YSTrH ---ITR -A@Y- (SECONDARY)

Coldwater Bd. Public Coldwater Coldwater 4-6 OPR 1940 Coal it Closed Cycle Well
Utility Cooling Tower
Mechanical Draft

Consoners Power Muskegon BC Cobb 1-5 OPR 1949 Coal 510 Once through, fresh Lake Muskegon IM)
Company (Muskegon River ID], Great
Lakes)

Consumers Power Comstock BE Morrow 1-4 OPR 1939 Oi 1 186 Once through, fresh Kalamazoo River
Com pan y

Consumers Power Charlevoix Big Rock Point 2 OPR 1963 Nuclear 72 Once throitgh, fresh Lake Michigan
Company AWR (Great Lakes)

Consumers Power Essexville DE Karn I & 2 OPR 1959 Coal 530 Once through, fresh Saginaw River
Com pan y (Lake Huron, Great Lakes)

Consumers Power Essexville nE Karn 3 OPR 1975 Oil 605 Closed Cycle Saginaw River
Company Cooling Tower (Lake thiron, Great Lakes)

Consumers Power Essexville DE Karn 4 OPR 1977 Oil 632 Closed Cycle Saginaw River
Company Cooling Tower (Lake Huron, Great Lakes)

Consumers Power Essexville JC Weadock 1-8 OPR 1940 OiJ 615 Once through, fresh Saginaw River
Company Coal (Saginaw Bay, Grent Lakes)

Consumers Power West Olive JC Campbell 1 2 OPR 1962 Coal 652 Once through, fresh Pigeon Lake I I I
Company (Lake Michigan JDJ)

Consumers Power Erie JR Whiting 1-3 OPR 1952 Coal 325 Once through, fresh Lake Erie
Company (Great Lakes)

Consumers Power Covert Palisades I OPR 1971 Nuclear 668 Closed cycle Lake Michigan
Company BWR Cooling Tower (Great Lakes)
Mechanical Draft

Detroit Edison Detroit Conners Creek OPR 1934 Oil 570 Once through, fresh Detroit River
Company Gas (Great Lakes)
Coal

Dp t ro i tEdison Detroit De I r a y OPR 1929 Oil 375 Once through, fresh Detroit River
Company Gas (Great Lakes)

Detroit Edison Newport Enrico Fermi I OPR 1960 oil 150 Once through, fresh Lake Erie 111
Company (Swan Creek DiR. Only,
Great Lakes)

Detroit Edison Avoca Greenwood I OPR 1979 Oil 800 Closed cycle Municipal Water IMI
Company Spray Canal (Black River IBD
Helper Pond

Detroit Edison Harbor Beach Harbor Beach OPR 1968 coal 121 Once through, fresh Lake Huron
Company Oil (Great Lakes)

a
b SOURCE: Atomic Industrial Forum, Inc., May 1980.
OPR - Operating status, STN = Standby status

MICHIGAN POWER PLANTSa (Cont.)
(OPR & STN)b
OPERATOR CITY PLANT NAME STATUS YEAR FUEL MEGAWATTS COOLING SYSTEM P R I MA R Y -CS-F C-0 N-D-A-R-Y7 ------

De t ro i t Edison Marysville Marysville OPR 1942 Coal 200 Once through, fresh St. Clair River
Company Cas (Lake St. Clair)

De L ro i t Edison Monroe Monroe OPR 1971 Coal 3150 jOnce through, fresh Raisin River
Company Oil (Lake Erie In])
Detroit Ed i son Riverview Pennwalt OPR 1926 Coal 37 Once through, fresh Detroit River
Company oil ftnke Erie, Great Lakes)
Detroit Edison Port Huron Port Huron OPR 1938 Coal 7 St. Clair River It]
Company (Black River [DI, Great
Lakes)

Detroit Edison River Rouge River Rouge OPR 1955 Coal 842 Once through, fresh Detroit River
Com pan y Oil (Lake Erie, Great Lakes)
Gas

Detroit Edison Belle River St. Clair OPR 1953 Coal 1620 Once throagh, fresh St. Clair River
Cam pan y Oil (Lake. St . Clair, Creat Lakes)
Gas

Detroit Edison Trenton Trenton Channel OPR 1949 Coal 738 Once through, fresh Detroit River
Company Gas (Lake Erie, Crest Lakes)
oil

Detroit Pub I ic Detroit Mistersky 1-6 OPR 1927 Coal 175 Once throtigh , fresh Detroit River
Lighting oil (Lake Erie, CreaL Lakes)

tj Detroit Public Detroit Mistersky 7 OPR 1979 oil 60 Once throngh , fresh Detroit Fivpr
Lighting Kake Erie, Great Lakes)

Dow Chemical Ludington Ludington 2 & 13 OPR 1944 14 ---

Ford Motor Company Wayne Power House One OPR 1931 Coal 345 Once thro,@gh, fresh River Rouge
1-7 Ga S (Lake Erie, Great Lakes)
Gladstone Light Utility Gladstone Gladstone I & 2 OPR 1955 Coal 6 Once through, fresh Little Bay DNo,:
(Lake Michigan)
Grand Haven Board of Grand Haven JB Sims I & 2 OPR 1961 Coal 20 Combination, once through Crand River
Light and Power Oil Helper pond, 24 acres (Great Lakes)

Holland Board of Holland James DeYoung 3-6 OPR 1951 Coal 83 Once through, fresh Lake Macatawn
Public Works Gas (Lake Michigan, Great Lakes)
Oil

Huron Cement Alpena 3-7 OPR 1920 Con 1 43 --- ---

Indiana & Michigan Bridgman DC Cook I OPR 1975 N, i c 1 e a r 1054 Once through, fresh Lake Michigan
Electric Company PWR (Great Lakes)
Indiana & Michigan Bridgman DC Cook 2 OPR t978 Nor I e ar 1054 Once throngh, fresh Lake Michigan
Electric Company PWR (Great Lakes)

a
b SOURCE: Atom ic Industrial Forum, Inc., May 1980.
OPR = Operati .ng status, STN = Standby status

MICHIGAN POWER PLANTS' (Cont.)
(OPR & STN)b
OPERATOR CITY PLANT _'@AME STATUS YEAR FU@L MEGAWATTS COOLING SYSTEM PRIMARY (SECONDARY)

Lansing Board of Lansing Eckert 1-3 OPR 1954 Coal 375 Combination, once through Grand River
Water & Light fresh, helper tower (Lake Michignn)
Mechanical draft

Lansing Board of Lansing Eckert 4-6 OPR 1954 Con 1 375 Combination, once through Grand River
Water & Light fresh, helper tower (Lake Michigan)
Mechanical draft

Lansing Board of Lansing Erickson I OPR 1973 Coal 160 Closed cycle, cooling Grand Ri ve r
Water & Light tower, mechanical draft (Lake Mich i gan)

Lansing Board of Lansing Ottawa Street 1-5 OPR 1939 Coal 82 Once through, fresh Grand River
Water & Light

Marquette Board of Marquette Shiras I & 2 OPR 1967 Coal 36 Once through, fresh Lake Superior
Light and Power Gag (Crest Lakes)

Michigan state East Lansing Shaw Lane I STN 1958 Coal 6 Closed Cycle well
University Cooling Tower
Mechanical Draft

Michigan State East Lansing Sixty-Five I & 2 OPR 1965 Coal 26 Closed Cycle well
University Gas Cooling Tower
Mechanical Draft

Northern Michigan Boyne City Advance 1-3 OPR 1967 Coal 37 Once through, fresh Lake Charlevoix
Electric Coop. (Lake Michigan)

Traverse City Light Traverse City Bayside 1-4 OPR 1949 Coal 33 Once through, fresh Grand Traverse Ray
and Power Gas (Great Lakes)

University of Ann Arbor University of OPR 1930 Gas 27 Closed cycle Mitnicipal Water
Michigan Michigan Cooling Tower
Mechanical Draft

Upper Peninsula Marquette Presque Isle 1-4 OPR 1955 Coal 175 Once through, fresh Lake Superior
Generating Company Oil (Great Lakes)

Upper Peninsula Marquette Presque Isle 5 & 6 OPR 1974 Coal 160 Once through, fresh Lake Superior
Generating Company (Great Lakes)

Upper Peninsula Marquette Presque Isle 7-9 OPR 1978 Coal 240 Once through, fresh Lake St,perior
Generating Company (CreAL Lakes)

Upper Peninsula Power Escanaba Escanaba I & 2 OPR 1957 Coal 29 Once thro,,gh, fresh Lake Michigan
Com pan y (Crent Lakes)

Upper Peninsula Power Lange JH Warden 1 OPR 1959 Coat 18 Once throitgh, fresh Lake Superior
Com pan y (Great Lake,,;)

White Pine Copper White Pine 1-4 OPR 1953 -- 58
Company

a SOURCE- Atomic Industrial Forum, Inc., May 1980.
b OPR = Operating status, SIN = Standby status

MICHIGAN POWER PLANTSa (Cont.)
(OPR & STN)II
OPERATOR CITY PLANT NAME --STATUS YEAR FUEL MEGAWATTS COOLING SYSTEM PRIMARY (SECOKITAMYT

Wolverine Electric Dorr VanDyke 6 OPR 1968 Oil 23 Closed.Cycle Little Rabbit River
Coop. Gas Cooling To.er (Big Rabbit River)

Wyandotte Department Wyandotte Wyandotte 2-5 & 7 OPR 1939 Gas 50 Once through, fresh Detroit River
Municipal Service oil (Like Eric, Crent Lakes)

tj
I
k-n

a SOURCE: Atomic Industrial Forum, Inc., May 1980.
b
OPR = Operating status, STH = Standby status

MICHIGAN POWER PLANTSa (Cont.)
(CON, PLN & I/p)b

OPERATOR CITY PLANT NAME STATUS YEAR FUEL MEGAWATTS COOLING SYSTEM PRIMARY (SECONDARY

Coldwater board Coldwater Coldwater 7 PLN 1982 Coal 25 Closed Cycle Well
Punlic Utility Cooling Tower
Mechanical Draft

consumers Power Hersey Hersey I I/P 1983 Wood 25 Closed Cycle Well IN]
Company Cooling Tower
Mechanical Draft
Fresh

Consumers Power West Olive JH Campbell CON 1980 Coal 800 Once through, fresh Pigeon River [I]
Company (Lake Michigan ID), Great
Lakes)

Consumers Power Midland Midland I CON 1985 Nuclear 504 Closed Cycle Tittabawassee River
Company PWR Cooling Pond 880 acres

Consumers Power Midland Midland 2 CON 1984 Nuclear 852 Closed Cycle Tittabawassee River
Company PWR Cooling Pond 880 acres

Detroit Edison China Township Belle River I CON 1984 Coal 697 Once through, fresh St. Clair River
Company (Lake St. Clair, Great Lakes)

Detroit Edison China Township Belle River 2 CON 1985 Coal 697 Once through, fresh St. Clair River
Company (Lake St. Clair, Great Lakes)
tj Detroit Edison Newport Enrico Fermi 2 CON 1982 Nuclear 1154 Closed Cycle Lake Erie
Company BWR Cooling Tower (Great Lakes)
Natural Draft

Grand Haven Board Grand Haven JB Sims #3 pin 1983 Coal 100 Combination once through, Grand River
of Light & Power Helper Pond, 24 acres (Grand River, Great Lakes)

Marquette Board of Marquette Shiras 3 PIN 1983 Coal 43 Once through, fresh Lake Superior
Power & Light (Great Lakes).

a SOURCE: Atomic Industrial Forum, Inc., May 1980.
b
PLIA = Planned, CON - under construction, I/P = Indefinitely Postponed

APPENDIX E

FACTORS AND POLICIES AFFECTING FUTURE COAL USE

A. FACTORS AND POLICIES ENCOURAGING COAL USE

1. State

a. Government

The State of Michigan has no official policies, laws, or
regulations which encourage coal use the state. The Department of
Natural Resources, Division of Land Resource Programs worked with
congresspeople and the Federal Office of Coastal Zone Management
to obtain amendments to the Coastal Zone Management Act (PL
93-457) that recognize coal as a major fuel moving to and through
the coastal zone and therefore eligible for additional planning,
construction and impact mitigation funds for its use, transport or
storage. This federal act became law in October, 1980.

The Michigan Energy and Resources Research Association
(MERRA), a partnership of Michigan state government, industry, and
universities, has made four recommendations related to coal to
state government which await action (MERRA, 1980): (1) establish
a Michigan coal advisory council as "an independent government
env ironmental-industry group dealing with all aspects of coal use
@n Michigan", (2) review state environmental laws affecting coal
use to establish "a reasonable balance between environmental needs
and the need to produce coal", (3) use a "total systems approach"
for coal development "to analyze the interaction of many
constraints inhibiting rapid coal production expansion, and to
ascertain the feasibility of given rates of expansion", and (4)
develop a coal transportation system "in anticipation of ...
future coal expansion transportation needs." If these
recommendations were carried out, they would serve as the base of
a state policy that could encourage the use of coal in Michigan.

b. Private

(1) Electric Utilities

The major utility company planners indicate that their
companies are seeking to use coal as much as possible and reduce
the use of oil and natural gas. Several steps in this process
tend to work against a,immediate big boost in coal use. For
example, the Detroit Edison Company purchases about 10 percent
(net) of i t spower from other utility companies in the
interconnected electrical grid. Making these purchases as needed
reduces the current need for additional "swing" or intermediate
power plants. However, when demand increases reserve capacity
will be reduced and additional plants will likely be needed,
possibly coal-fired plants.

E-1

TABLE E-1

COAL-CAPABLE UTILITY PLANTS IN MICHIGAN
BURNING OIL OR GAS AS OF JANUARY 1980 a

ACCORDING TO THE U.S. DEPARTMENT OF ENERGY

utility Plant b Unit,

Consumers Power Co. Weadock 4 5 6
Karn * 3 4
Morrow 1 2 3 4

Detroit Edison Delray 11 12 12
14 15 16
St. Clair 5
River Rouge I
Conners Creek 89 10
12 13 14

Wyandotte Dept. of Municipal Service Wyandotte 4

a This list covers plant ordered to burn coal under the Energy Supply and
Environmental Coordination Act (PL 93-139) and the Powerplant and
Industrial Fuel Use Act (PL 95-620).
b All plant except Morrow and Wyandotte are located in coastal counties of
Michigan.

NOTE: In the review of this report before final publication, the Consumers
Power Company indicated that:

(1) Weadock units 1-6 were converted from coal firing to oi.1 firing a
number of years ago. The coal handling and processing equipment was
removed and disposed of. Weadock 1-6 are no longer capable of burning
coal.

(2) Karn units 3 & 4 were designed and built to burn crude oil. They are
now burning residual oil. Company studies indicate that a derate from
600 to 300 megawatts each would result, due to the furnace design, if
the burning of coal was attempted. For this and other reasons, these
units are not capable of burning coal.

(3) Morrow units 1-4 were converted from coal burning to oil burning
several years ago. More recently the units were placed on gas fuel
which is the situation today. The coal handling and processing
equipment was removed and disposed of. These units are no longer
capable of burning coal.

E-2

Twenty-four units currently burning oil or gas at plants of
the Detroit Edison Company, Consumers Power Company and the
Wyandotte Department of Municipal Service are capable of being
converted to coal (Table E-1 p. D-17) and are under government
order to convert. While these units collectively have
considerable capacity,.their age and technology might otherwise
preclude conversion to coal. Some of them (e.g., River Rouge 1)
are not regularly used because of the cost of oil. Furthermore
the capital cost of a new coal-fired boiler plant is about two 'to
three times that of a gas or oil-fired plant (MERRA, 1980, p.
126). If conversion orders are carried out on these units, coal
use would be increased. The latest technology would reduce costs
of operation. Eighty-three percent (20 out of 24) of the units
ordered to be converted in Michigan under the Energy Supply and
Environmental Coordination Act are located in coastal counties.
If these units were placed in regular service due to increased
demand for electricity, utility company long-term contracts for
coal will encourage coal transportation and unloading in
Michigan's coastal areas.

A recent report of the World Coal Study suggests that future
pollution control technology will be capable of meeting stringent
environmental controls for coal emissions (World Coal Study,
1980). The availability of this technology will encourage the use
of coal, particularly at large plants which will benefit from
economies of scale.

(2) Other Industries

Currently, thirty-one manufacturing, chemical, and cement
firms with forty-seven plants in Michigan use coal. Eight of
these plants are also set up to burn oil or natural gas. The
Powerplant and Industrial Fuel Use Act prohibits the use of oil or
natural gas in new industrial boilers without an exemption from
the U.S. Department of Energy (DOE). The law also requires
industrial plant capable of using coal or coal-oil mixtures to
convert. Administration of this latter requirement will determine
future coal use by industry. A recent study of industrial
conversion potential suggests that conversion by industry other
than utilities will be limited. The principal changeover to coal
will take place in the electric utility industry.

Pollution control technology is available. While this
technology is expensive, relative costs are dropping. The
efficiency of sulfur dioxide scrubber technology has increased
substantially since the early 1920's (Academy for Comtemporary
Problems, 1977). As the price of other fuels rises, this
technology will be more attractive; thus, in the short-run, coal
use will not rise rapidly by industry, but in the long-run coal
use is expected to expand considerably.

Amajor factor affecting increased use of coal in the state is
the application of coal use and conversion technologies. The
Department of Energy does not project low-BTU coal gasification

E-3

facilities in southeast Michigan by the year 2000 (See Table E-2).
Low to medium BTU gasification as well as high BTU gasification
and synthetic oil production is expected to be insignificant in
the state through 1985 (MERRA, 1980). Also, fluidized bed and
combined cycle technologies which increase energy efficiency and
reduce emissions problems may also encourage coal use in the
process. The technologies are expected to be applied by 2000
(Table E-2).

MERRA projects that "... 67 million tons is considered the
most probable amount of coal that will be consumed in Michigan
during 2000 AD. This is 2.3 times the current amount. The
effective range of variation is considered to be between 53-80
million tons. Similar to the national coal consumption scenarios,
the attainment of this 67 million ton Michigan consumption level
assumes that major breakthroughs will be achieved within the next
several years in regard to the constraints now impeding coal
production and consumption.

The use of coal for electrical generation in Michigan will
most likely range between 37-47 million tons per year in 2000 AD
(about 1.8-2.2 times the current level). The industrial use of
coal in Michigan will most likely range between 10-20 million tons
per year in 2000 AD (about 2.5-5.0 times the current level)."
(MERRA, 1980)

2. Regional

a. Government

Future use of coal and its transportation through or to
Michigan is partly affected by policies and actions in surrounding
states and the nation. Illinois, Minnesota, New York, and Ohio
have policies supporting and encouraging coal research and
development, including (1) coal gasification and liquification,
(2) fluidized-bed combustion, and (3) reduction of pollution
(Great Lakes Basin Commission, 1980). The mining policies of
Illinois, Indiana and Ohio are designed to reduce environmental
problems with coal extraction, thereby making the mining of coal
more environmentally attractive (Great Lakes Basin Commission,
1980). The policies will encourage the use of coal and its
transportation throughout the region. Michigan will benefit from
the research results obtained in other states. A conference to
examine the prospects of exporting Indiana coal to foreign users
was held in July 1980. While export of coal through the Great
Lakes was not a major focus of the meeting, other organizations
and firms have considered this possibility.

A review of capacity at Michigan ports and docks as well as
other U.S. Great Lakes ports shows sufficient collective capacity
to accomodate a doubling or tripling of coal movement through
them. Some individual ports and docks may not have capacity to
double or triple throughput.

E-4

TABLE E-2

DEPARTMENT OF ENERGY P ROJECTED

EMERGING ENERGY TECHNOLOGIES IN THE GREAT LAKES BASIN
(by major lake basin to the year 2000)

TECHNOLOGY LAKE BA9'fg--

Hydroelectric
Small-scale/low-head x x x x x x x
Pumped Storage x x

Coal gasification - low BTU x

Enhanced Oil Recovery x x x x x

Solar
Solar Thermal x x x x x
Comm./res. heating/cooling x x x x x x x x
Ind. process heating x x x x x x x x

Biomass
Urban Residue x x x x x x x x
Agric/Silvi. x x x x x x x x

Advanced Coal Combustion
Fluidized Bed x x x x x x x x
Combined Cycle x x x x x x x x

1 SOURCE: U.S. Department of Energy, Interim Draft Energy Technology Scenarios
for Use in Water Resources Assessments under Section 13a of the
Federal Non-nuclear Energy Research and Development Act, Washington,
D.C., September 1980.

E-5

Should iron ore production level or only slightly increase due
to less demand for steel in smaller cars, the locks at Sault Ste.
Marie would have sufficient capacity well beyond the year 2000,
even with an extended winter season on the upper Great Lakes (U.S.
Army Corps of Engineers, 1980). The locks on the Welland Canal
would not be able to accomodate additional coal expansion beyond
the mid 1980's (U.S. Army Corps of Engineers, 1980). The St .
Lawrence Seaway has adequate capacity for substantial shipments of
coal to foreign destinations. (U.S. Army Corps of Engineers; St .
Lawrence Seaway Development Corporation, 1980).

Western Coal Movement - Argonne National Laboratory
studies (Argonne National Laboratory, 1979) concluded that by
1999 western coal delivered to the east would be competitive
due to the expectation of rising eastern rail rates because of
financial difficulties of eastern rail roads. Conversion to
low-sulfur coal by small industries already using coal would
not be costly. Factors of the existing transport network most
affecting potential ind.ustrial and utility users of western
coal are: (1) the capacity at the Sault Ste. Marie locks, (2)
the closing of the lakes during the winter i.ce, and (3) the age
of the Great Lakes fleet. However, if winter navigation
continued, Argonne Labs concluded that it could potentially
reduce the area needed to stockpile coal along coastal
locations which depend on western or eastern coal delivered by
lake vessel . In the long run, the cost difference between
eastern and western coals delivered to midwest utilities is
small enough that limitations on western coal movement could be
reversed depending on the implementation of the new source
performance standards and the lowest achievable emission rate
for non-attainment areas. While the Argonne Lab study saw no
immediate need to greatly expand port facilities, air quality
regulations and transportation diregulation could change this
situation by 1985. That study concluded that lakeshore
utilitlies would be more likely to use western coal.

Another study (ICF Incorporated, 1978) examining the
demand for western coal subject to key uncertainties concluded
that: (1) higher priced coal (due to severance taxes, etc.),
(2) higher rail rates in the west, and (3) higher labor rates
in the west would reduce the potential demand for western coal
in the east but not elminate this demand. Higher oi.1 prices
would obviously increase western coal demand. If the new
source performance standards for sulfur emissions required only
partial scrubbing would reduce the incentive to use western
coal but not eliminate it. One problem with the models used in
this study of western coal demand as well as other national
studies of coal use previously done is that they have assumed
that the world price of oil would rise much more slowly than it
has (e.g., $30/barrel by 1985). If these models were rerun
with current prices, coal demand may be projected to be much
greater in the future.

E-6

b Private

Shipping companies are actively seeking coal export contracts,
but not necessarily through the Great Lakes. The major
conclusions concerning coal transportation through the Great Lakes
are that: (1) In the short-run the Great Lakes could pick up
traffic due to the congestion at coal-shipping docks on the east
coast. This would be temporary because the Norfolk and Baltimore
facilities will be expanded (Lake Carriers' Association; Federal
Commerce and Navigation, Inc., 1980), (2) The St. Lawrence Seaway
and Great Lakes ports currently serving eastern and western coal
on the Great Lakes will receive this increase in traffic only
until east coast ports can handle the traffic. The reason for
this is the increased cost of shipping coal through the Great
Lakes to foreign destinations. Increases in costs are due to
several factors: use of smaller lake vessels (30-33,000
deadweight tons (DWT) versus 60-100,000 DWT for oceangoing
vessels) with higher unit transport costs, tolls on the Seaway,
and if the coal on smaller vessels is transshipped to larger
vessels at some point along the St. Lawrence River, transshipment
costs to consolidate shipments, and rail rates which discriminate
against Great Lakes ports (Federal Commerce and Navigation, Inc.;
St. Lawrence Seaway Development Corporation, 1980). The advantage
of moving coal through the Great Lakes-Seaway system during this
time of east coast congestion is that waiting time and demurage
costs would be reduced.

Federal Commerce and Navigation, Inc., a bulk commodity
shipping company with offices in Chicago, is building four vessels
of 36,000 DWI for general cargo and coal trade. These are sized
to serve Great Lakes and overseas trade (Federal Commerce and
Navigation, Inc., 1980).

Any transport of western coal in the near future through the
Great Lakes would probably originate in Superior Wisconsin and
pass through the Sault Ste. Marie Locks and St. Marys River and
then through the St. Clair River, Lake St. Clair and Detroit
River. Eastern coal would likely move out of an Illinois,
Indiana, Ohio, Pennsylvania or possibly New York Great Lakes port.
The Pennsylvania Governor's Energy office has considered the
possibility of serving some New England plants forced to convert
to coal out of the Port of Erie and through the St . Lawrence
Seaway.

Electric utility companies usually obtain long-term (e.g., 20
years) contracts for coal to be delivered at their plants so that
they have a reliable fuel supply. As new growth in demand and
conversions to coal take place, long-term contracts will be made
with coal companies and transportation companies. This activity
will ensure that more coal can be supplied in the future. It also
provides incentive rail lines and shipping lanes. Table E-3 shows
the plants in the Great Lakes states ordered to convert to coal.
Twenty-one percent of these units are located along the shoreline
of the Great Lakes basin and will receive all of their coal

E-7

supplies by water or rail transport through the coastal zone.
Long-term contracts will result in delivery of coal in the coastal
zone for many years..

As industrial and utility coal conversion progresses and
greater demand for the fuel materializes, transshipment facilities
in the state of Michigan could develop. Such facilities could
serve as a type of "coal broker" to coal users in areas such as
southeastern Michigan when the large amounts of storage space
necessary for extensive coal use can be problematic. Southern
Michigan may in fact contain likely sites for such transshipment
facilities; which would operate basically by receiving coal from
vessels and unit trains, storing this coal at their site until
needed, and then supplying space constrained users by way of local
transportation connections. In this way, greater use of coal as
an energy source may be realized in facilities currently unable to
afford the commitment of many acres to coal storage.

While coal as a fuel for vessel transport has received renewed
interest nationally, in the Great Lakes region it is not clear
what the future of coal is as a fuel for the commercial water
sector. Several aspects of future coal use by vessels need
attention, including (1) future availability of oil for the
maritime industry, (2) possible use of coal-oil mixtures, (3)
steam power plants which can alternate between coal and oil, (4)
whether overboard flyash disposal would be permitted, and (5)
methods to control smoke emissions from vessels burning coal.
(Cleveland-Cliffs Iron Company, 1980).

The concept of tug-barge transport and delivery of coal could
expand the number of locations which could receive coal by water
due to substantially less draft required by barges (12 feet or
less). Whether this will actually result in more coal use of
increased water delivery of coal in the near future i. s
speculative.

3. National

a. Government

The federal government has enacted several laws over the last
seven years intended to increase the use of coal while protecting
the environment. These laws include (1) the Energy Supply and
Environmental Coordination Act of 1974, (2) the Powerplant and
Industrial Fuel Use Act of 1978, (3) the Federal coal Leasing
Amendments Act of 1975, (4) the Energy Reorganization Act of 1974,
and (5) the Energy Tax Act of 1978. These laws are reviewed in
detail in Appendix C. The research and development programs for
coal use in the U.S. Department of Energy and the Environmental
Protection Agency also are directed toward increasing coal use in
an environemntally acceptable way. Most recently, the synthetic
fuels legislation will provide greater emphasis to convert coal to
liquid and gaseous fuels at locations distant from coal mines and
where water availability is adequate. This latter factor suggests

E-8

.increased coal conversion in the Great Lakes basin as noted in
Table E-2.

From a regulatory standpoint, ordered coal conversions under
the Energy Supply and Environmental Coordination Act and the
Powerplant and Industrial Fuel Use Act will also increase the use
of coal by electric utilities and industry. Conversion orders are
for existing plants burning oil or natural gas that are capable of
burning coal to convert to coal. Also, new plants must be
designed to burn coal. The burden is on the company to prove why
it should not convert its coal-capable plants(s) to coal. See
Table E-3.

Current abandonment policies of the U.S. Department of
Transportation for rail lines give priority to fossil-fuel
(essentially coal) lines to be maintained and subsidized. Current
and potential fossil-fuel transport is considered in these
decisions. This policy encourages coal use and the maintenance of
coal supply lines.

Official federal transportation policy does not address water
transport of coal in terms of maintain shipping lanes or giving
preference to shipments of coal in navigable water or through
locks. The Coastal Energy Impact Program under the Coastal Zone
Management Act (as amended) does provide grants to states (1) for
the study of and planning for any economic , social, or
environmental effects of the transportation and storage of some
fuels, but not necessarily including coal and (2) to assist in the
prevention, reduction, or amelioration of unavoidable loss to the
coastal zone of valuable environmental or recreational resources
resulting from (among other coastal energy activities) the
transportation, transfer or storage of coal. Thus, the Coastal
Zone Management Act (CZMA) provides possibilities for closely
examining coal transport, unloading and transshipment in the
coastal zone but does not raise coal as a priority national fuel
as do the other recent federal energy laws. The extent to which
coal can be examined and its transportation effects mitigated is
subject to funds available to states under a formula that favors
outer continental shelf (OCS) oil and gas. While the nation must
diversify its fuels sources, the thrust of the CZMA is to increase
dependence on fuels of relative lesser abundance rather than
assisting in an evolving national policy that places priority on
using the nation's abundant coal resources. Therefore, the CZMA
passively and indirectly encourages coal use by providing ways to
ameliorate the effects of its use, but through implementation does
not assist in promoting an even-handed comprehensive,
enironmenLally and economically balanced approach to coal use that
will affect many communities in the country due to the need for
transportation to coal-using locations. Many communities in which
coal will be used or expanded in use, or through which coal will
be transported, are located in the coastal zone of the Great Lakes
and other coasts.

E-9

TABLE E-3

COAL-CAPABLE UTILITY PLANTS BURNING OIL OR GA�
I'@ THE GREAT LAKES STATES AS OF JANUARY 1980-1-
ACCORDING TO THE U.S. DEPARTMENT OF ENERGY

STATE UTILITY PLANT UNIT

Illinois Central Illinois Public Serv. Hutsonville 12
Commonwealth Edison Collins 45
Ridgeland (GLB) 1 2 34
Illinois Power Co. Wood River 1 23
Havana 1 2 3 45
Iowa Illinois Gas & Electric Moline 5 67
Union Electric Venice #2 1 23
4 56
University of Illinois Abbott 1 2 34
5 67

Indiana Indianapolis Light & Power Stout 34
Pritchard 12

Michigan Consumers Power Co. Weadock (GLB)* 4 56
Karn (GLB)* 34
Morrow (GLB)* 1 2 34
Detroit Edison Delray (GLB) 11 12 13
14 15 16
St. Clair (GLB) 5
River Rouge (GLB) I
Conners Creek(GLB) 8 9 10
12 13 14
Wyandotte Dept. of Wyandotte (GLB) 4
Municipal Service

Minnesota Austin Utilities Austin 1 2 3 4 5
Interstate Power Fox Lake 1 2 3

New York Central Hudson Gas & Electric Danskammer 1 2 3 4
Consolidated Edison Waterside 4 5 6 7
8 9 14 15
East River 5 6 7
59th Street 13 14 15
74th Street 3 9 10 11
Hudson Avenue 5 6 7 8 10
Arthur Kill 23
Astoria 1 2 3 45
Ravenswood 1 23
Long Island Lighting Company Barrett 12
Far Rockaway 4
Glenwood 45
Northport 1 2 34
Port Jefferson 1 2 34
Niagara Mohawk Power Albany 1 2 34
Oswego (GLB) 1 2 34
E-10

STATE UTILITY. PLANT UNIT

New York (Con't)
Orange & Rockland Utilities Lovett 1 2 3 4 5

Ohio Dayton Power & Light Tait 1 2 3 7 8

Pennsylvania Philadelphia Electric Cromby 2
Delaware 7 8
Chester 5 6
Richmond 9 12
Schuykill 1 3 9
Southwark 1 2
West Penn Power Springdale 7 8

a This list covers plants ordered to burn coal under the Energy Supply and
Environmental Coordination Act (PL 93-139) and the Powerplant and
Industrial Fuel Use Act (PL 95-620).
b The parenthetical note (GLB) after a plant name indicates plants in the
Great Lakes basin (hydrologic area).

NOTE: In the review of this report before final publication, the Consumers
Power Company indicated that:

(1) Weadock units 1-6 were converted from coal firing to oil firing a
number of years ago. The coal handling and processing equipment was
removed and disposed of. Weadock 1-6 are no longer capable of burning
coal.

E-11

From a coal export standpoint, no clear federal policy has
evolved However, "the United States will remain one of the
world's largest coal exporter and by the 1990's could become the
world's balancing supplier of steam coal." (World Coal Study,
1980, p. 117). In order to accomplish this and recognizing that
transport costs are a significant factor in the cost of delivered
coal , port infrastructure needs will require major attention
nationally and internationally (World Coal Study, 1980, p. 38) .
More ships that can tranpsort dry bulk as well as oil will be
needed. 11 During the 1980's the major part of coal in seaborne
international trade is expected to be carried in vessels of about
100,000 - 125,000 DWT. During the 1990's, ships as large as
250,000 DWT may come into use." (World Coal Study, 1980, p.41).
Coal ports will have to provide adequate berths and draft depths.
With some international ports possibly becoming distribution
centers and with the need to reduce long ocean distances by using
the international canals, such as the Panama Canal, the mix of
vessels used in international trade will probably include smaller
ships of 65,000 - 75,000 DWT as well as barges and smaller coastal
vessels . (World Coal Study, 1980, pp. 41-42) The vessel size
requirements may preclude many Seaway-sized ships entering the
international coal trade, except for use in consolidating coal for
transport in larger vessels at a port along the St. Lawrence
River. Regional-national projects such as the All-American Canal
proposal to connect Lake Erie and Lake Ontario with a new canal or
a new canal from Lake Erie to the Hudson River will probably be
designed to serve vessels similar to those plying the Great Lakes
and Seaway currently (Corps of Engineers, Reference). Thus, these
proposed canals will continue to reinforce use of the Great Lakes
and Seaway as water feeder routes to ports serving larger coal
vessels. As noted previously, it appears that the Michigan and
Great Lakes ports have adequate capacity to handle substantially
more coal.

2. Private

The price of coal relative to other sources of energy will
probably be the major factor influencing the future use of coal.
If that price is low enough, potential users may be able to
justify using it regardless of any constraints in processing or
burning it might present. Nationally, three hundred forty-nine
electric generating units located at one hundred four powerplants
in twenty-four states and the District of Columbia are
coal-capable and currently burning oil or gas. The conversion of
these units along with coal capable plants in other industries
provides impetus nationally to use more coal. This will also
place greater demands on the coal transport system.

From an export standpoint, the United States could export
more than 20 percent of its coal production and still have
adequate reserves to meet domestic demand (World Coal Study, 1980,
p. 115). Coal mining companies would want long-term contracts.
Currently, U.S. coal priced -at $50/ton is one-third cheaper to
import than OPEC oil with equivalent energy content. (Wall Street

E-12

Journal, July 25, 1980) These circumstances will encourage future
coal production as well as place further demands on the coal
transport system. Currently most of the coal being shipped to
Western Europe and Japan from east coast coal ports is mined at
eastern coal mines. This coal moves by rail to these east coast
ports. Already congestion from foreign ships attempting to pick
up coal is a major problem. The Great Lakes ports do present a
reasonable but more expensive alternative in the near term until
east coast ports are expanded.

Factors Increas,ing the Demand for Electricity.

Electric power generation accounts for about two-thirds of
the coal used nationally and 70 percent of the coal used in
Michigan. (MERRA, 1980) Increased demand for electricity over the
next twenty years will result from a number of factors working
together:

1'. Increased population - As the population increases in 'size,
a greater demand will exist for the products and services
of business and industry. Therefore, residential,
commercial, and industrial electrical demand will increase
in some proportion to population.

2. Rising standard of living - If the standard of living
r i s e s ,a greater re I ianc e on appliances which use
electricity to do work and entertain can be expected.

3. Appliances - While appliances are being produced to use
electricity more efficiently, the utility companies expect
the installation of air conditioning equipment in homes and
businesses to increase, thus increasing electrical demand.

4. Car production - As domestic auto production and the use of
steel and metals increases, the demand for electricity in
these plants will increase.

5. Electric Vehicles - Electric utility company projections
indicate that the electric car is expected to significantly
increase electric demand as soon as the mid-1980's. A
combination of reduced operation cost over gasoline driven
cars, improved battery technology to reduce battery
replacement costs, and the benefit to the auto companies of
being able to increase their corporate average fuel economy
by producing electric cars, is expected to provide the
stimulus to produce and purchase electric cars. The
utility companies anticipate that the use of electric
vehicles will be the largest factor increasing the demand
for electricity in the future. See Table E-4.

6. Mass transportation - While use of mass transit, people
movers and light rail/subway systems is expected to
increase, the utility companies do not anticipate big
increases in electrical demand to result.

E-13

TABLE E-4

PROJECTIONS FOR ELECTRIC CARS

Year Production Used in Michigan (8%) Used in SE Michigan (4%)
(Thousands) (Thousands) (Thousands)

1985 50-100 4 - 8 2 - 4

1988 2,500-5,000 200 - 400 100 - 200
1990 5,000-10,000 400 - 800 200 - 400

1995 10,000-20,000 800 - 1600 400 - 800
2000 12,500-25,000 1000 - 2000 500 - 1000

NOTES: CorporaLe average fuel economy equivalent for electric vehicles:
80-100 miles/gal.

Assumed Average Customer Use:

6-7,000 kwh/year/vehicle (1980)
3-4 cents/mile - operation (electricity) (1980)
$3000/battery (1980)
$8-10,000 purchase price of vehicle (1980)

E-14

B. FACTORS AND POLICIES CONSTRAINING COAL USE

1. State

a. Government

The State of Michigan is developing and has adopted a number of
policies that would reduce expected increases in coal use. These
policies (1) encourage conservation (appliance labeling,
prohibition of continously burning pilot lights, conservation
grants for pub I ic buildings, building surveys and audits,
restrictions on interior building temperatures, energy education,
prohibition of declining block rates, restrictions on lighting
levels, restrctions on the use and sale of energy resources,
industrial energy audits, encouragement of residential energy
audits, establishment of a low-income household weatherizati.on
program, and tax credit for heating fuel costs;) (2) ban the sale
of decorative lamps which use natural gas; (3) prescribe oil-energy
conservation projects for public buildings; and (4) encourage
renewable sources (a wood energy program, tax credit for hydropower
and solar installations, solar energy education program, tax
exemption for solar equipment sales and use, tax exemption for
solar installations, tax credit wind energy instal lat ions). (Great
Lakes Basin Commission, 1980) These policies and programs reduce
reliance on fossil-fuel and nuclear energy, the conventional energy
sources.

b. Private

Utilities and other industries cannot be converted quickly to
coal. The expense will limit conversion to coal from oil or
natural gas. Michigan industry will also be affected by factors
at the regional and national level. Table E-5 provides an overview
of factors constraining conversion to coal by industry. The
utility sector uses 70% of the coal in Micbigan, and wi.11 therefore
dominate future use of coal in the state. The large Michigan
utilities have revised their average annual growth rates of
electricity demand from the 7% figure used in the early 1970's to
2.5% to 2.75% for the period from 1980 to the mid 1990's. The
emergence of solar energy is also expected to slow the rate of
electricity demand by a small but significant amount. Over the
next 15 years, solar energy is expected to provide about 3% of what
otherwise would have been demand for electricity in Michigan.
Over the same 15 years, incremental conservation by electricity
users and improved appliance efficiency are expected to similarly
reduce electricity demand.

2. Regional

a. Government

The Great Lakes states have established and continue to develop
official policies to provide more energy while reducing oil
dependence. These policies would discourage or replace coal by
other energy sources.
E-15

TABLE E @ 5

SUMMARY OF

MAJOR CONSTRAINTS AFFECTING U.S. COAL PRODUCTION EXPANSION

I .Status of air quality laws and regulations, projects. Railroad opposition to such projects
particularly those pertaining to sulfur emis- and the need for remedial legislation in this
sions. area.
2. Need to find environmentally, technologically, 12. Mining equipment problems, lead times for
and economically sound methods of using mining equipment delivery.
high-sulfur coal. 13. Lead times for opening a sufficient number of
3. Coal user problems-ie., the lack of sufficient new mines to meet anticipated or desired coal
incentives to switch voluntarily to coal. expansion schedules.
4. Rail and barge transportation system limits 14. Availability of skilled labor for mining expan-
and the need to expand and improve these sion.
systems. 15. Establishment of new towns and com-
5. Threat of "horizontal divestiture" and its n@unities as "support systems" for western
potential effect upon coal industry capital strip-mining projects.
formation. 16. Availability of water in the West for mining-
6. Stability of labor and labor productivity in the support communities, mining operations, and
coal industry. any synthetic gas or liquefaction projects.
7. As yet uncertain effect of federal strip-mining 17. Capital formation for coal-based synthetic gas
laws. projIects.
8. Adequacy of land reclamation technology in 18. Waste disposal and acid-mine drainage
the semiarid regions. problems.
9. Need for adequate leasing programs-ie., 19. Recoverable resource appraisal: The real size
putting large blocs of reserves together in the and availability of recoverable mineable re-
East and accelerating federal and railroad sources should be reevaluated. A new and
land leasing policies and schedules in the thorough look at the current "proven" re-
West. source figures is needed.
10, Mine productivity problems and the need for 20, The need to find better and quicker legal and
better mining techniques and "systems." regulatory means of certifying large-scale
11. Coal slurry lines-roadblocks to right-of-way energy projects while giving fair considera-
acquisition for potential coal slurry pipeline tion to all reasonable environmental issues.

Source: Michigan Energy and Resources Research Association.

E- 16

The capability of the region's transportation system to continue
to supply coal needs to be examined. If rail cars are not
available due to competition for their use by other regions, for
coal export, or for other commodities, coal delivery could be
constrained and coal use discouraged. A study for. the state of
Michigan recommends a transportation system analysis to assess
future coal transportation needs.

b. Private

As the private sector applies other technologies which conserve
energy or use renewable energy sources, demand for coal will be
reduced. As application of these technologies becomes more
widespread and the technologies become more refined and less
expensive, an increasingly larger portion of industry will more
toward their application.

The postponement of certain coal-fired facilities due to a
decrease in demand for electicity, primarily from conservation, has
the effect of constraining future growth in coal use.

3. National

a. Government

Federal pollution control laws (particularly for so 2 emissions),
laws encouraging other energy sources, and mining laws do work to
discourage the use of coal. However, after a period of relative
decline in the importance of coal in the nation's energy economy,
coal use is increasing in spite of these laws because the cost of
producing it is competitive with oil.

However, the original survey done in 1977 for the Power Plant
and Industrial Fuel Use Act found that of the 6,200 industrial
boilers covered by the act, 780 were coal capable and 752 would be
exempted under some provision of the act. Thus, private industry
conversion in response to this act will probably be law.

b. Private

Several factors will affect industry. Price and availabili.Ly of
coal and other fuels will be most important. A factor limiting
expanding coal use is that coal is now "demand constrained" (MERRA,
1980). That is, in comparison to the amount that could be supplied
at existing prices, current demand is low. This market factor
results from costly conversion from other fuels to coal, capability
of the transportation system, the relatively low cost of other fuel
given the high cost of converting plants to coal, the uncertainty
of the future use of coal, the design, investment and construction
of coal plants cannot occur immediately, and environmental
considerations which may be regulated in the future thereby
increasing the cost of using coal.

E-17

Table E-6 shows expected coal development production stages
related to supply and demand.

TABLE E-6

Coal Production Development Stages

INITIAL PERIOD Now through 1985 EQUILIBRIUM PERIOD About 1992
Coal production limited primarily Deliverable coal supply and demand
by the lack of demand. are essentially balanced for several

years.

TRANSITION PERIOD After 1985 SUPPLY-CONSTRAINED PERIOD After 1992

Demand starts expanding as energy Coal demand greater than the readily
shortages develop in other sectors. deliverable supply because of
Demand starts catching up to environmental restrictions and
supply-delivery capacity. constraints on mining, labor, trans-
portation, and delivery.

E-18

Other environmental problems of burning coal and the challenge
of meeting them could cause a much slower movement toward expanding
coal use than previously anticipated. Environmental hazards of
coal consumption include "emission of sulfur dioxide, nitrogen
oxide, trace elements (including arsenic, cadmium, mercury, lead,
fluroine, and beryllium), and carbon dioxide into the atmosphere,
thermal and chemical discharges into water and the soli.d-waste
disposal problems of coal ash." (Stobaugh and Yergin, 1979) the
process of sulfur dioxide removal also generates a sludge; however,
only new sources of sulfur dioxide emissions must have scrubbers to
remove this pollutant, so only new plants will be affected by this
problem.

The cost of pollution control for SO 2 control from burning coal
constrains coal use. However, the efficiency of the technology has
improved substantially and the relative cost has dropped.

Potential labor strikes in coal fields similar to those of the
1970's present obstacles to expanded use of coal by industry.
These strikes present fuel supply interruptions which the companies
must be prepared to respond to by spending capital for stockpiles
.or by using alternative, and higher cost, fuel sources (Stobaugh
and Yergin, 1979). Companies may plan to rely on a mix of fuels to
have "some protection against monopoly pricing, strikes, embargoes,
weather effects." (Stobaugh and Yergin, 1979)

Table E-7 summarizes major factors affecting U.S. industrial
boiler conversion to coal.

Due to the high costs of converting to coal from other fuels
(noted earlier), coal will be economically attractive only for
large industrial boilers operating aL high load factors and where
economies-of-scale and fuel costs offset higher annualized
operating costs. (U.S. Environmental Protection Agency, 1980)

E-19

TABLE E-7

FACTORS AFFECTING INDUSTRIAL BOILER CONVERSION TO COAL

1. Capital cost are double for coal technologies than for oil and gas

2. Coal cannot be burned in boilers designed for liquid or gas fuels (the
boilers must be rebuilt for coal combustion)

3. Coal-based technologies require more space for boilers, pollution control
equipment, coal handling and residual disposal

4. Operating and maintenance costs are 2 - 5 times greater for coal than for
oil and gas units

5. Unit costs are high for small users

6. Incremental boiler needs will not be meet by coal because of high
capital, operating,and maintenance costs

7. 45 to 90 day supply of coal reserve requires 5 - 10 additional acres of
land

8. Flyash transport and disposal adds extra cost

9. Coal use usually requires access to rail connections or shoreline

10. Transport costs for coal are higher, more uncertain, less predictable for
coal than for oil and gas

11. For small users, single car shipment cost can be double unit train costs

12. Unit trains require large land area and often plant redesign for coal
delivery

13. Coal producers can lose money on long-term contracts with small users

14. Variations in coal fuel quality can cause boiler operating problems

15. Coal has supply reliability problems due labor strikes and inclimate
weather which require plant redundancy

16. Long-term coal contracts lock industrial users in on technology, plant
location, and size of investment

17. Coal-fired boilers and pollution control equipment require shutdowns for
cleaning and parts replacement

18. Coal will probably not be used as a redundant or back-up system because
of installation capital cost.

19. Advanced pollution control requires added technical personnel

E-20

TABLE E-7 (CON'T)

20. Investment in conversion to coal will be less productive and will create
an opportunity cost

21. The quality of some products may be affected because of the varying coal
fuel quality

22. Fludized bed combustion of coal is cost competitive for large boilers,
provdes efficient heat transfer, suppresses sulfur emissions, but results
in large solid waste volume to dispose of.

ABSTRACTED FROM: U. S. Environmental Protection Agency,
Industrial Boiler Technologies to the
Year 2000, 1980

E-21

Factors Reducing Demand for Electricity

As noted earlier, the electric utility industry accounts for
over two-thirds of all coal use. Factors which might work to
reduce demand for electricity over the next 20 years include:

1. Conservation - Conservation in all sectors is making a real
difference in electrical demand. Large reductions in the
rate of increase in demand have been made. Utility companies
expect these reductions due to conservation to gradually
reduce to zero by the late 1980's.

2. Alternative sources - Alternative sources of energy, such as
solar or biomass, will reduce the demand for electricity from
large central generating plants. Some of the sources will be
used to produce electricity at smaller decentralized
locations, but reduce the demand for fossil and nuclear
fuels. Utility companies do not expect solar or wind power
to significantly reduce electrical demand.

Generally in the United States and in Michigan the annual growth
rate of electric demand fell from about 7 percent to 3 to 4
percent. Detroit Edison and Consumers Power Companies are
currently using a range of 2 to 3 percent for projections in the
1980's .

Factors Perpetuating The Status Quo

1. Industry capital problems - In Michigan, industry has had
capital formation problems due to business conditions. The
capital that is available is put into priority production
items, like retailing, and will not be put into conservation
measures as it would be otherwise.

2. Car production - electricity is used in the production of
cars. The effect of the reduction in size of cars is
expected to be offset by an increase in the number of cars
sold. This, however, assumes that as the price of gasoline
rises and people drive cars less, the increase in population
will support the demand for more small cars.

E-22

APPENDIX F

THE COAL PRODUCTION-CONSUMPTION CYCLE

Although this study focuses on the effect of coal unloading and
transshipment on Michigan's coast, other aspects of the coal
prod uc L ion-consumpt ion cycle may constrain coal movement. The total energy
system--available resources, mining/extraction, transportation, energy
conversion and consumption-end use--must be examined to identify impacts on
coal unloading and transshipment. This section describes that larger energy
system. Figure F-1 gives an overview of this system.

F-1

FIGURE F-1

THE COAL PRODUCTION-CONSUMPTION CYCLE

Resources Coal Mining Preparation
Location Coal Type Characteristics
Appalachian Anthracite Sulfur Underground Crushing
North Bituminous Ash DF14AND Conventional Screening
South FOR Continuous
Interior Subbiturninous Moisture COAL Shortwall Conventional cleaning
East Lignite Heat Content Longwall Physical desulf urization
West Chlorine Surface Advanced desulfurization'
Western Area
North Contour
South Auger

Transportation End Use
Customer Combustion
Train Utilities Pulverized coal
Regular freight Industry Grates & stokers
Unit train Residential/ Fluidized bed*
Barge Commercial
Truck I
Conveyor belt
Slurry lines*
Steam or electric'
transmission

-This system undergoing research and development in the U.S.
-Can bt@ considered an alternative to coal transportation in getting the energy to the final point of use.

SOURCE. Office of Technology Assessment.

F@2

Demand for Energy

Future energy demand is difficult to ascertain. Several variables
interact to establish energy demand forecasts of the total quantity of energy
demanded uncertain. To project a range of energy demand it is necessary to
speculate on the future level of economic growth, the actions of consumers,
rate of population growth, anticipated prices of various fuels,. and the levels
of energy efficiency and conservation. The level of aggregate demand, the sum
of resident ial/commerc i.al , industrial, and transportation energy demand must
be determined in order to establish the demand for coal.

The aforementioned variables and the level of aggregate demand are
the driving forces behind the coal product ion-consumpt ion cycle. Coal
unloading and transshipment are part of the cycle and as such are affected by
changes in the variables. Although the relationship may not be completely
obvious, basic understanding of the entire cycle may illuminate some of the
major faCLors encouraging or constraining coal use in Michigan, and therefore
affecting coal unloading and transshipment.

Mining of Coal

The two general methods of mining coal are surface mining and
underground mining. Surface mining exposes the coal seam by removal of the
overburden (soil and rock). Four basic methods of surface mining are used:
area, open-pit, auger, and contour mining (Office of Technology Assessment,
1979).

Underground mining is more difficult than surface mining. Instead of
stripping the overburden and trucking the coal away from within the mine,
underground mining is conducted under thick overburden by means of shafts and
passageways. Due to the nature of underground mining, pillars of coal must be
left in the shafts to support the overburden roof. The deeper the mine, the
larger the pillars must be relative to the -mined-out areas. In some cases,
less than 50% of the coal seam can be removed.

Coal production in the Appalachian region has annually supplied 60%
or more of total national production since mining began in the United States.
Surface mine reserves are insufficient to support present production rates for
more than a decade. The remaining recoverable underground reserves are large
but substantial portions may remain unmined due to the high cost of mining
than in comparison to the price of other fuels. This coal is generally the
highest grade bituminous but it often has a high sulfur content (office of
Technology Assessment, 1979).

Eastern interior regional coal is produced i-n a number of small mines
with relatively high annual production rates. Indiana, Western Kentucky, and
Illinois have annually supplied from 20-25% of total national production for
several years. The greatest portion of the total remaining recoverable
reserves for underground mining occurs in beds underlying previously mined-out
areas. Illinois has very large underground reserves remaining. Surface mine
production has remained essentially constant in this region for a number of
years and present production rates are expected to be maintained for several
years. The heat content of this coal tends to be slightly lower than
Appalachian coal and the sulfur content can be quite high (Office of
Technology Assessment, 1979).

F-3

Underground mining has virtually ceased in the western interior
region which includes the states of Arkansas, Kansas, Oklahoma, and Iowa.
Surface production has remained relatively constant in these areas but the
amount produced is insignificant. Generally, the coalbeds are thi.n.
Production in this region is unlikely to increase significantly in the near
future (Office of Technology Assessment, 1979).

The western states contain approximately 67% of the national,
recoverable, surface-minable reserves. The reserves are relatively
undisturbed . The beds are the thickest in the nation except for Pennsylvania
anthracite beds. The western states of Colorado, Utah, Montana, and Wyoming
contain approximately 43% of recoverable underground reserves. The most
productive portions of the coal fields of Utah, Colorado, and Wyoming have
undergone substantial depletion, yet many relatively unmined areas remain *
Increases in underground production are expected in Utah, Colorado, Wyoming
and Montana; however, underground recovery of as much as 50% of the thicker
beds may be difficult with present technology. Most western coal is
subbituminous or lignite. It has a substantially lower heat content
(aproximately 10%-15%) (MERRA 1980) and higher moisture and ash content than
eastern coal . The sulfur content is low (Office of Technology Assessment,
1979).

Until recently, the eastern Appalachian region has been the primary
source of coal for Michigan. This is largely because it has been readily
accessible, economical, transportable, and environmentally acceptable.
Legislation concerning sulfur emissions has prompted the use of low sulfur
western coal by some Michigan utilities. Michigan's situation in the Great
Lakes basin offers an economical method of transporting western coal once it
has been moved to the western end of Lake Superior. Given this advantage, it
is anticipated that Michigan will be capable of using a greater percentage of
low sulfur western coal to meet the demand for coal. Recent trends appear to
support tnis assumption. In 1978, 12.3% of Michigan's coal supply came from
the West compared to 4% in 1975 (MERRA, 1980).

Periodically, attention is given to Michigan's remaining coal
reserves. Coal production began in the state in the 1860's and continued
until 1952. A total of 46,316,580 tons was mined during this period. The
remaining known bituminous reserves total 126.5 million tons and are located
in the central part of the lower peninsula. The coal seams are thin,
discontinuous, and high in sulfur.. The quality of the coal is significantly
lower than that of the Appalachian region or the eastern interior region, the
major sources of coal for the state (MERRA, 1980). The risks by the economic
and technical problems associated with mining the coal discourage serious
consideration of this option at the present time.

Table F-1 indicates projected national coal production by region.
Table F-2 indicates the sources of coal for Michigan.

F-4

TABLE F-I

PROJECTED U.S. COAL PRODUCTION BY REGION
(Million Tons)

Rrx:ioN 1975 199") 1990

NCA* KpyqloNr.:" pm.-lixim A*
f1li'l. -F
1111,fon 7 of 11111. X or till]. X of 11111. X of tvill. 7 of
Tons Totnt Ton q Totnt To its Tot a Totiq To Ln I Tonq To La 1. Tonn Totn.1 Tonn To t.n I T"nn Tota I Toii!% Tot n

ArPALACIVIA 395 61, 399 39 it 5 5 3 to 426 113 to I in 451 38 401 36 441 29 /4 6 ft 25

fII.DI-IE,I;T t02 75 ZOO 19 7 1 to 19 7/97 75 779 75 M 24 356 32 27 445 24

'WEST 91 14 1952 ill 610 47 .117 37 It 02 16 ff.") 1. .39 156 32 669 44 947 .51

TOTAI, 6118 too 14151 100 1119 100 990 TOO 11.16 TOO 1113 IT TOO 1. t 1, 4 100 1. 5 2 1 TOO 1,1356 1,00

ProdoctIon enttitnteq nrn hatird viTion anotoitoced nrw mine niirvpyq h,V the flntloiinl Coril. AnnorInt fon nod Koyritoeip Conl
Infloqtry Sotrvey; they do not project Cc? 19170.

DOE Lensinp Potiry Developmefit Offire (I.PDO) prnlortq n rsimo of prottlirl Inn eptimnlipit. "imaher." 111.1y not ndA dtie
to rotindInR.

COAL, A DATA 11(10K

The Prrnldetnt's Commin.91tiot 011 Ctini r. 91

Assumptions and factors affecting the projecLion of coal production
include:

1) Coal Consumption is expected to be about I billion tons in 1985
and 1.1 - 1.3 billion tons in 1990.
2) Western coal production is expected to increase from 250% to 600%
during the period 1975-1985.
3) Medium economic growth of 3% per year will occur; energy will be
available at medium levels with constant real oil prices; no
change in the national ener.-y policy will not change.
4) Regional market shares wit[ depend upon such factors as
transportation costs, demand for low-sulfur coal, and changes in
EPA sulfur emission standards.
5) Low sulfur Western coal will lose much of its advantage over
Eastern coal after 1985 if EPA regulations mandate stack gas
scrubbing for plants coming on line.

TABLE F- 2

SOURCES OF BITUMINOUS COAL AND LIGNITE FOR MICHIGAN

1976 1.978 1970
J I z " --I
Source (District)* 1000 Tons of Total 1000 Tons z rf Total 1000 -rons f Total

Fastern Kentuckv QI-220 30.3 0 4 37.7 13,867 42.8

On i o 8.141 27.4 5.248 19.0 4,567 14.1

Northern W. Virginial 5,382 18.1 4,056 14.7 4.843 15.0

Montana 2,887 9.7 3,407 12.3 4,359 113.5

We-;tern Kentuckv 1,354 4,5 422 1.5 476 1.5

3.8
Southern W. Virginia; 1,189 4.0 1,014 3.7 1,242

Pennsylvania 787 2.6 2,094 7.6 2,080 6.4

Various 845 2.8 965 3.5 950 2.9

Total 29.80"; Imn 27.608 100.0 32.385 100.0

*Bureau of mines Bituminous Coal and Lignite production Districts

Source: I) 4ichigan Statistical Abstract. David I. Verway (editor).
Division of Research, Graduate School of Business Administration, MichiRan State University. 1979.

2) Energy Information Administration. U.S. Department of Energy. Energy Data Reports, 1979.

F-6

Coal Transportation

Once the coal is mined and processed, it is moved to another site for
combustion. "Minemouth" facilities are served by trucks and belt conveyors.
Long distance transport is by highway, railroad, waterway and slurry pipeline.
Transportation cost is a major determinant of the specific mine source or
combustion site. Table F-3 presents projected coal transporCation for the
nation.

Truck Transport

The fastest growing mode of coal transportation is by truck. During
1975, 79 million tons or 12% of all coal produced nationally was moved from
mine to market by truck. In 1976, 89.8 million tons or 13% was transported by
truck. Projections suggest that 12% of all coal produced nationally in the
year ZOOO will be moved by truck. This projection is equivalent to a tonnage
increase of approximately 50% over 1975 levels (U. S . Department o f
Transportation, 1978).

There are significant regional variations in movement of coal by
truck. During 1975, for example, 81% of truck transported coal was loaded in
the Appalachian region. An additional 14% originated from other eastern
areas, with the remainder, approximately 5% loaded in all other producing
regions combined (U.S. Department of Transportation, 1978).

Trucks the collection and distribution functions of mine-to-market
movement. Trucks operate in short haul situations rather than as long
distance carriers since trucking costs more than other modes for long hauls.
The average highway shipment of coal is 50-75 miles compared to an average
haul of 300 miles by rail and 480 miles by barge (Office of Technology
AssessmenL, 1979). Locally, highway capacity and vehicle weight restrictions
further limit opportunities for trucR, transport.

Truck transportation of coal is limited in Michigan. The only
significant truck transport of coal in Michigan occurs at Traverse City where
the municipal utility receiving docks are several miles from the generating
plant. Coal is delivered to the docks by water and then trucked to the plant.

Railroad Transport

Railroads transported approximately 420 million tons or two-thirds of
total U.S. coal production in 1975. Projected coal tonnage transported by
railroads in the year 2000 expected to increase by 1.4 to 2.4 ti.mes the 1975
tonnage (U.S. Department of Transportation, 1978).

Railroads generally load the coal at or near the mine and deliver the
coal directly to the destination point; this is particularly true for eastern
rail transport. The continued development of western low sulfur coal
production is also projected to significantly increase the frequency of coal
transport by rail to the western Great Lakes port facilities for transshipment
(U.S. Department of Transportation, 1978).

The average hopper car carries about 75 tons of coal. Older cars
carry approximately 55 tons, compared to the newer hoppers which carry 100
tons at capacity. The complete cycle of loading, hauling to the unloading
point, unloading and returning for another cargo averages 13 days for each
car. The size of the hopper cars that can be accomodated depends on road

F-7

TABLE F-3

PROJECTED NATIONAL COAL TRANSPORT MODES*, 1985

MODE Million Tons by Mode Percent of Total Moved

1975_ 1976 1985 2000
ZEI 30.4 YE? EE1 BOM

RAiL 418 503 637 08 1,023
431.1 730 6
657' 63.5% 64.5% 64. 63% 64.57 64.5%

YOTOR 79 89.8 95 120 144 115 193
VEHICLE 127 13.27 12 . 2'!.' 12.2% 12% 12.27 l2f@

MINE !OU_H 74 79 2 39 113 132 107 i8i
G EN-ElU T I.NG 11.. 11.7% 11.4% 11.4% 11% 11.4% 11.4%

WATER*** 69% 69.6 i 83 106 132 101 170
11 10.3% 10.7% 11% 10.7!@ 10.7%

OrHER** 8 8.9 1 9 12 12 11 19
1 1.37 1.2% 1.2% 1% 1.2% L.27

TOTIAL 648 678.6 779 11 988 11,200 942 1,586

1
NED - National Energy ?Ian
B OM - Bureau of Mines
EEI - Edison Electric Institute
Primary Transport made used to move coal from mine to final destination.
Includes coal used at mine, taken by locomotive tenders at tipple, used
at mine'for power and heat; coal transported from mine to point of use
by conveyor or tram; coal made into behive coke at mine; all other uses
at mine; and coal shipped by slurry pipeline.
Includes barge transport on inland rivers and lake vessel transport on the
Great Lakes.

SOURCES: Coal: A Data Book
The President's Commission on Coal, p. 195. 198()-
National Energy Transportation, Volume III-Issues and Problems,
report prepared by the Congressional Research Service, March 1978,
P. 58.

The assumptions for projected coal transport to the year 2000 include:
1) Railroads are expected to remain the dominant transport mode
through 1985 since long haul movement of coal will increase. By
1985 total rail transport of coal will increase by approximately
2/3 over current levels.

2) Western rail transport is expected to increase 300 to 400 percent
by 1985., Increases in unit train movements are expected,
particularly in the West.

3) Western coal may move by water after it is railed to ports on the
Great Lakes and the Mississippi River. Increased tonnage will be
shipped to Detroit via the Great Lakes, Chicago via the Illinois
waterway, and the South and Southwest via the Mississippi,
Tennessee and other rivers.

4) No critical problems in terminal/ transfer capacity, fleet
expansion, or equipment supply are anticipated through 1985.

5) Major constraints to growth of coal traffic on traffic on inland
water-ways are inadequate luck capacity, limited channel depth
and the age of the Great Lakes fleet.

6) Percent shares of coal transported by primary mode (i.e. moving
the coal most or all of the way from mine to final destination)
will remain virtually constant through 1985: rail = 65%; highway
- 12%; water = 11%; mine-mouth generating plant consumption - 11%
and slurry pipelines and other
F-8

conditions and the weight the trac k can support . Western coal unit trains
tend to use 100-ton hopper cars; Eastern shipments often require 55-ton
hoppers.

The growth of western coal production has encouraged the use of unit
trains. The unit train is designed to take advantage of economics of scale.
It generally carries a single commodity in dedicated service between two
points is sufficient volume to achieve cost savings. A typical coal unit
train consists of six 3,000 horsepower locomotives and 100 hopper cars with
carrying capacities of 10 tons each. Roughly two such trains per week are
required to deliver approximately one million tons of coal per year (Office of
Technology Assessment, 1979). Unit trains are most used as frequently east of
the Mississippi River because eastern coal generally originates from smaller
mines and travels shorter distances. Also the weight capacity of eastern
tracks is limited (U.S. Department of Transportation, 1978). Many experts
believe that rail transport of coal nationally is presently close to physical
capacity. Expansion of coal production has to be accompanied by expansion of
the railroads' ability to handle the shipments. Substantial investments will
be necessary to accommodate the expected increase in coal tonnage transported
by rail (MERRA, 1980). Investments include between $5 and $7 billion to
purchase and replace rail cars, $4 - $5 billion to upgrade and build new
track, and $300 million for new right-of-way for access to coal reserves (U.S.
Department of Transportation, 1978; President's Commission on Coal, 1980).

Water Transport

Water transportation of coal, including barge and lake vessel,
accounted for 69 million tons or 11% of all coal shipments loaded during 1975.
Projected tonnage for the year 2000 is expected to be between 115 to 193
million tons, representing approximately 10.7% of national production
(Congressional Research Service, 1978).

During 1975, 39 million tons of coal were shipped via the Great
Lakes. This represents approximately 18% of the total tons of coal shipped
through the inland waterways. Exports to Canada accounted for approximately
45% of the 1975 total tonnage for the Great Lakes. The 1978 tonnage was 37.7
million reflecting a general downward trend in Great Lakes tonnage since the
mid'1960's (Lake Carriers Association, 1978).

Single self-propelled bulk cargo carriers are used on the Great
Lakes. The average lake carrier capacity is 20,000 tons (Office of Technology
Assessment, 1979). The Detroit Edison Company of Michigan currently uses
three 1000 feet long vessels with an average capacity of 62,000 tons of coal
each. They are self-unloading vessels which deposit the coal directly unto
the dock or into dock hopper . On its first run, one of the ships - the Belle
River, carried 66,550 tons of coal (National Academy of Sciences, 1979).

The projected increase for Great Lakes coal traffic in 1985 is an
additional 5.6 million tons amounting to approximately a 14% increase over
1975 tonnage. This figure represents domestic coal movement only; it does not
include exports to Canada (U.S. Department of Transportation, 1978).

F-9

The general consensus is that terminal/transfer capacity for all
waterborne coal traffic is adequate to 1985. Within the Great Lakes region,
the Duluth-Superior and Conneaut, OH transshipment facilities are expected to
experience the greatest growth in coal handling (U.S. Department of
Transportation, 1978).

However, several constraints on future transportation of coal via the
Great Lakes have been cited. The most frequently cited are lock capacity
and the limited water navigation season. (President's Commission on Coal,
1980). The question of whether these are coal-specific constraints has not
been adequately addressed. Some investigation of the benefi.Ls and costs of
increasing coal storage capacity as compared to expanding lock capacity or
extending the navigation season may be warranted.

Slurry Pipelines

Coal slurry pipelines are expected to function in the coal
transportation system by the year 2000. The major current economic and
technical difficulties inhibiting slurry pipeline development are expected to
be overcome by that time. Legal difficulties ensue over the issue of eminent
domain for slurry pipelines right-of-way across railroad routes.
Environmental and legal issues surface in the acquisition of water required to
transport the coal by pipeline. The major coal slurry projects involve
transporting large volumes of coal from the western states where water
resources are limited. The potential water restrictions to slurry pipeline
development has led to technical innovations such as water recycling through
looped pipelines. Currently, the economic costs of recycling outweigh the
benefits. Another frequent suggestion to remedy the water problems is the use
of an oil-coal slurry mix (WOCOL, 1980). A major resurgence in the demand for
coal has not yet m 'aterialized. Significant pressure to develop slurry
pipelines is not likely to occur unti.1 the present delivery systems become
strained under strong increases in oal demand (MERRA, 1980). However, it
should be noted that lobbying efforts are underway in support of the Coal
Pipeline Act of 1979 which is currently in the House Committee on Public Works'
and Transportation (personal conversation, Slurry Transport Association, June
1980). Table F-4 and Figure F-2 describe existing and projected coal slurry
pipeline systems.

F-10

TABLE F-4

COAL SLURRY PIPELINES

A nnual 11@afc
Pipeline S.%%tem l,cn1!1h Capacit% Operatinnal urrew Slaw,

Lximiri

1. Black %lesa Pipeline- 4.8, IT) opcranon
since 197 1.
From Peahod % Coal Co', Blaj
%Ile@a Mine in northeastern Art-
/Ona to ihe 1,580 M%k Niolia%c
generating i;iation in Ne%ada.

2. Ohio Pipeline- 108 1.3 Closed. Built and operaied h on@olidaiion C,ial
Co. for 6 %car, trom 191- to 1963. 1he
From Cadiz. Ohio to) Lake Eric. Pipeline clo Wd follo'Alm-, reduction (if rail
rates.

Planned or Under Stud,.

3. Allen-Warner Valley Energy Environmental impact Statement in procew
System No additional Legislation required for right-
of-,Aav acquisition.
Consv;tinc of i\%o independent
pjpelines.
ls@ 9.1 1985-1988
a. From Alion coal field, South-
ern Utah to the 2000 NI'lik Har-
r@ Allen plant near Las %egas.
%evada.
198.
13 2.5
In. From .50ton coal field, South-
ern U tah i o t he 500 \1 W %% arn-
er \ allc' plant near Art-
zona,'Ne% Mexico Border.

1,355 25.0 1984 Environmental impact Statement in proccs;.
4. ETSI Pipeline- Pending completion of the EIS. Energ\
Transportation S -vstems, Inc. is conductins! a
From Wyoming's Powder River coal slurry marketing program, preparing
Basin to a barge terminal at Pen- coal evaluation facilit71'es and securine .1g .nt@-
ion, Mississippi, with an optional of-%;a\.. (in thepast two years. ETSI filed and
extension of the pipeline from won 65 different suits against variou@ rai!-
Arkansas to southern Louisiana, roads to secure crossings beneath their trazk;.
Three of those \ ictories. challeneed in hicher
courts, have been confirmed on appeal).

5. Florida Pipeline- 40-55 1986 Continental Resources (formerl\ Florida Gas
Company), working with si\ Sciuthea;iern
Two gathering systems are under utilities, has determined that a coal pipeline
consideration to serve utilities in to Georgia and Florida would reduce sub-
Georgia and Florida. One system stantial]\ coal transportation costs to that
would originate in the coal fields area. Water requirements are minimal com-
of Kentucky, West Virginia and pared with available supplie5 in the originat-
Virginia; the other in Illinois, Ten- ing areas, but enactment of eminent domai In
Y acqui-
nessee and Indiana. legislation is necesat% for right-of-wa%
sition.

6. Snake River Pipeline- 1.1W 10.0 Indefinite Proposed in 1974 by Northwest Energy Com-
pany and Gulf Interstate Engineering Com-
From Wvomirnz and Montana to pany on the basis of anticipated coal demand
the Pacifi.c Nort -hAcst and Idaho. that has not de\eloped, this project is beins:
held in abeyance. pending de\elopment of a
demand for coal.

F-11

TABLE F- 4 (Con't)

Annual Date
Ungsh capadil Operational Currtni Status
I'Miles) (Million Tons)

645
Pacific Buik Transportation 10,43 IrIdTfinile Proposed b@ Boeing arid COII-
S%slcm- 5truchort. Compan@, to transport coal to the
West Coast and export it to the far East.
Froin Emery, Utah iv@ Port Hue-
tic'me. Calif ornia@

San Marco Pipeline- 900 15.0 1995 The San Matco Company, A Par' InershiP Of
HoustOp Natural Gas Cornpan% and Rio
From Soui horn Colorad,,s to Hous- Crandt industries (parent compan@ of the
Denver Rio Grande Western Railroad), is
awaiting adjudication in the Colorado 1% atel
Court Of its request for the use of @%atcr@ A
pretria) hearing date has been set in late 1980,
since most of the pipefine route would be in
Texas, which approved eminent domain for
coal pipelines in 1911, right-of-way acquisi-
tion is riot considered a major problem.

Te,@a,, Ea5iern Pipeline- 1.260 25@O Indefinite Texas Eastern Transmission Corripzn@ Pro-
posed this pipeline in 1979. and the company
Sou*,N-rn Montana and northern is investigating possible wait, sources. A
\omin@: !o Texa, Gulf coa,@i water development project, approved by the
Wyoming irgislature, was dropped when the
State's governor dechried to enter into a feasi-
bility stlidy required by, the iegislation.

SOURCE: 1979 Coal Traffic Annual National Coal Association, 1980.

F-12

FTGURE F-2

COAL SLURRY PIPELINE SYSTEMS

- ---------4
Vji llette

46 -*Cl-evelan
7
Las too 3 Denvar *,04 Wichita
Vega

Little* t I a n t;t',.
Rock
9
G5

ton
Existing Pipelines 40 Rouge
ouston

Planned Pipelines monwassmonsmans Miami

Proposed Pipelines .............................

Pipeline Corridors Studied

1. Black %lessa
2. Ohio
3, Allen-Warner Valley Energy System
4. ETSI
5. Florida
6. Snake River
7. Pacific Bulk Transportation System
S. San;Marco
9. Texas Eastern

Source: Slurrv Transport Association

SOURCE: 1979 Coal Traffic Annual National Coal Association, 1980.

F-13

Coal Consumption

The consumption of coal depends on such variables as the price
relative to other fuels, cost attractiveness of conversion from other fuels,
environmental controls, and national policy for synthetic fuels and
alternative energy sources. The most widely used national projections are
from the first and second National Energy Plans (NEP-1 and NEP-II). Wh ich
supposedly reflect current energy policies. The projections of fuel use in
the second National Energy Plan are shown below, along with the main economic
assumptions .

A discussion of these projections and energy projections for the
state of Michigan is provided elsewhere in this report and will not be
repeated here.

F-14

APPENDIX G

ENVIRONMENTAL EFFECTS

This Appendix is a concise statement of the potential environmental
effects of activities related to coal transshipment and unloading. First, an
overview of the chemical and physical aspects of coal is given. Ef fects on
soils, water quality, air quality, animal and plant communities and aesthetics
are surveyed . At the end of the appendix are tables that give a brief
description of the major activities related to coal transshipment and
unloading.

AN OVERVIEW OF THE CHEMICAL AND PHYSICAL CHARACTERIZATION OF COAL

Coal can be defined as a sedimentary rock consisting mostly of
compounds of carbon, hydrogen, oxygen, and a large portion of volatile matter.
(Neavel et al 1977) Most of this volatile matter is composed of hydrocarbons
and water . As the rank (state of metamorphosis) of the coal increases the
percentage of volatile matter decreases and the percent of fixed carbon
increases. (Carlson et al 1979)

During formation, coal undergoes a continuous series of alterations
given by: living plants -- peat -- lignite -- subbituminous coal --
bituminous coal -- anthracite. Each step results in an increase in the
relative amount of carbon present, with up to 93% to 98% carbon for anthracite
coal. (Carlson et al 1979)

For practical purposes, coal is categorized by "proximate" analyses,
which are empirical tests. A proximate analysis of coal involves
determination of four constituents: 1) moisture; 2) ash; the residue from
complete combustion, 3) volatile matter, consisting of gases or vapors driven
off when coal is heated (9600 for 7 minutes) and 4) fixed carbon, the solid
residue that remains after the volatile matter is driven off, less its ash
content. (Szabo, 1978)

Moisture, sulfur, and ash, are undesirable constituents of coal.
Volatile matter and fixed carbon produce most of the energy when coal is
burned.

The rank of coal increases as the amount of fixed carbon increases
and as the amounts of inherent moisture and volatile matter decrease.
The great variation in composition of coals is apparent in the following
analysis (ash-free basis) of a typical Lignite & Anthracite in %

Lignite Anthracite

Fixed Carbon 33 92
Volatile matter 26 5
Moisture 41 3

Total 100 100

(Szabo, 1978)
G-1

Coal is composed not only of those elements usually considered to be
organic (C, H, N, 0) but also contains significant quantities of inorganic
elements. (Gluskoter et al 1977)

The organic matter is a complex mixture of various macromolecules
which varies according to the rank. The inorganic material in coal including
major, minor, and trace elements is difficult to measure but may account for
3% to 31% of the coal matter (Gluskoter et al 1977). The study of inorganics
in coal (mineral matter) has intensified since the 1960's because several
elements and minerals such as berylium, mercury, and asbetsos have been
recognized as hazardous to human health, and others have been suspected of
being detrimental to the environment. (Dvorak et al 1978)

Mineral matter is incorporated into coal in two ways: (1) deposition
from water percolating through decaying vegetation in early stages of coal
formation and (2) infiltration of cracks and fissures in the formed coal
during subsequent stages. (Braunstein et al, 1977)

Knowledge of the background concentrations of these inorganics,
(major, minor, and trace elements in the environment) is important for
assessing the possible threat from anthropogenic sources. Natural levels are
found in the soil, water, and atmosphere, but the forms and concentrations in
each medium are different. (Braunstein et al, 1977)

The following sections contain in depth discussions of the major
effects of transportation to, and construction and operation of, a coal
unloading and transshipment facility.

EFFECTS ON SOILS

The effects of coal dust in soils will be important primarily in
areas along transport corridors and areas adjacent to coal storage piles.

0 Coal Dust - Coal dust may cause changes in the chemical properties of the
soil, and may affect aboveground portions of the plants intercepting the
coal dust. (Dvorak, et al 1978) The degree to which soils are altered is
dependent on the buffering capacity of the soil. The buffering capacity
of soils originating from carbonaceous sedimentary parent materials is
high, but it is low for soils formed from granites and quartzites.
(Dvorak et al, 1978) A lowering of the soil pH causes a decreas e2+in 4T
cation 2V change capacity of the soil, and cations such as Mn4-, Ni , Fe
and Ca are leached from the soil profile. Also, increased acidity may
result in increased availability of zinc and aluminum, (such that these
elements become toxic to plants) and decreased availability of phosphorus.
(Dvorak et al, 1978) The effects of acidity on the soil can be
ameliorated by applications of lime.

In humid regions where soils are generally acid, additions of alkaline
coal dust (western coal) may lead to an increase in soil pH. If such
increases exceed the pH range of tolerance of native plant species,
changes in vegetation can occur. Also, raising the pH of the soil changes
the availability of nutritive elements such as phosphate, iron, and
manganese, possibly leading to deficiencies in these ions. (Dvorak et al,
1978)
G-2

Coal dust may also liberate small amounts of trace elements to the soil .
For plants, the potential toxicity of trace elements in coal within the
soil depends largely on whether or not the element is available (present
in the soil in a form that can be absorbed and assimilated by growing
plants) .

Availability is dependent upon the interactions of many factors including
the properties of the trace elements, the soil, and the plants, the
biological characteristics of the soil, and environmental parameters such
as temperature and precipitation. (Dvorak et al 1978) All of the
interrelationships of these factors are unknown.

The major impact on the soil from construction and transportation is
fugitive dust generation from unprotected earth surfaces. Fugitive dust
can clog the interstitial spaces of the soil and prevent downward movement
of precipitation, resulting in an increased runoff. (Dvorak et al, 1978)

EFFECTS ON WATER QUALITY

Coal and coal dust may be important in waterbodies adjacent to coal
transport lanes and nearshore operating areas including loading/ unload ing,
storage, and handling operations.

� Coal Dust - Coal is essentially an insoluble solid. When coal is in the
ground aquifers run through the seams and leach virtually all of the
soluble material from the coal long before it is mined. Hence, all of the
soluble constituents of coal are lost in a historical sense. When raw
coal (usually in the form of dust) enters a body of water it tends to
adsorb rather than release organic pollutants. (Communication, W. C.
Sonzogni) Therefore, few organic constituents of coal should be liberated
in water and should not be significant even in local areas. Also, no
extreme toxics or heavy metals are expected to be released from coal in a
waterway. Depending on the hardness of the water, the rank (stage of
metamorphosis) of the coal, and the coal seam and basin, small amounts of
elements such as aluminum and boron may be released to a waterway.
(Communication, R. M. Carlson) Neither of these elements are considered
extremely toxic or dangerous in water at low concentrations, and hence
should not present a significant problem with regard to coal.

� Resuspension of. Sediments - (caused by; dredging, dredge material
disposal, and vessel movement)

Resuspension of bottom sediments by dredging and ship traffic is an
important secondary source of turbidity in a waterway. (Sydor et al ,
1980) Suspended solids due to resuspension average about 5 times the
usual concentration of suspended solids in a waterway. The major concerns
of resuspended sediments are the possible release of toxic materials from
the sediments, and increased turbidity, causing the disturbance and
destruction of benthic organisms and habitat resulting in changes in
species composition, distribution, and abundance. (Corps of Engineers,
1974)

G-3

� Increased Turbidity (caused by; coal dust and fugitive dust in
suspension, erosion, dredging, dredge material disposal, and construction)

Turbidity is primarily a matter of aesthetic impact rather than biological
impact. (Corps of Engineers, 1979) However, increased turbidity may
lower the overall biological productivity in a waterway by contributing to
a decrease in light penetrati-on. This lowers the suitability of the area
for aquatic vegetation because of a decrease in photosynthetic activity.

Also, turbidity may impact fish spawning grounds and habitat and cause the
temporary out-migration of motile aquatic species which utilize the water
near the site. (Corps of Engineers, 1979) Increased turbidity may also
contribute to the displacement and destruction of benthic organisms by
clogging respiratory and feeding surfaces, and changes in the chemical
equilibrium at the sediment - water interface. (Commerce Division, Long
Beach Harbor Department, 1978)

� Change in pH - (caused by increased coal dust in the waterway)

Changes in pH in a waterway may occur locally due to increased coal dust.
Eastern coal has a high sulfur content and may lower the pH of the water
slightly. Western coal has a high carbonate base and may raise the pH of
the water slightly. It is generally believed that raw coal in a waterway
will not influence the pH significantly except possibly in areas where the
coal to water ratio is high, such as around docks. (Communication, R. M.
Carlson) The major concerns of pH changes are the possible adverse
effects on aquatic vegetation, benthos, and fish.

� Reduction or Change in Aquatic Vegetation - (caused by; increased
turbidity, coal dust, and change in pH)

The suitability of an area to support aquatic vegetation will be reduced
due to a decrease in light penetration resulting from increased turbidity.
(Roy F. Weston, Inc. 1974) The reduction in light penetration reduces the
photosynthetic capabilities of the plant. Some species of algae might
benefit from increased turbidity due to decreases in dissolved oxygen
levels. (Commerce Division, Long Beach Harbor, 1978) Zooplankton
populations could be secondarily affected owing to decreased amounts of
vegetation.

� Reduction or Change in Benthic Communities (caused by; dredging, dredge
material disposal, turbidity and change in pH)

The importance of benthos to the entire food-web of an aquatic envi .ronment
has been well recognized for many years. They are important ecologically
because they serve as food for fish and other benthic organisms and are
essential in the decomposition of organic sediments. (Commerce Division,
Long Beach Harbor, 1978) After displacement, benthic organisms will
recognize the bottom areas, although possibly in reduced numbers.

Turbidity associated with coal related activities may damage or kill
organisms on the bottom, on sheet pilings, and in the water column, by
clogging respiratory and feeding surfaces. Also, benthic organisms may be
eliminated by toxic effects either directly through exposure to the toxic

G-4

material , or indirectly by limited algal food supplies (Commerce
Division, Long Beach Harbor, 1978)

0 Reduction or Change in Fish Populations - (caused by; dredging, dredge
material disposal, turbidity, change in pH, and change in water chemistry)

The most extensive studies on aquatic impacts from coal facilities have
been on fish. Acidity is an important water quality parameter when
discussing fish survival and productivity in an area. The mechanisms
involved in acid-induced effects will vary depending upon the leyls of
acidity and interactions with other components. (e.g., metals and CO

In the pH range of 4 to 5 (more often encountered in waterways affected by
acid rain) fish mortality occurs due to he disturbance of normal ion and
acid-base balance. (Dvorak et al, 1978)

The pH range of 4.5 to 4.7 will have adverse effects on lake herring,
yellow perch, lake chub, carp, and salmonid eggs and fry. A pH of 4.7 to
5.2 is harmful to brown bullhead, white sucker, and rock bass. A pH of
5.2 to 5.5 is harmful to lake trout, and trout-perch, and a pH of 5.5 to
6.0 is harmful to small mouth bass, walleye, and burbot. A pH of between
6.0 and 9.0 is harmless to most fish. (Dvorak et al, 1978)

Coal related activities will impact fish populations in other ways as
well. Fish populations and growth rates might be reduced due to lowered
amounts of food items. Reproductive success among fish spawning in the
area might be diminished as a result of increased turbidity. Behavioral
patterns of fish could change due to mechanical disturbances associated
with vessel loading and unloading, and increased turbidity. Finally, the
flesh of fish caught near the facility could potentially be higher in
concentrations of some heavy metals. (Corps of Engineers, 1974)

EFFECTS ON ATR QUALITY

Although the major air quality concerns are with the burning of coal,
the transportation and storage aspects also contribute to various atmospheric
impacts. The major ones are:

0 Emissions - (caused by; vessels, trains, trucks, construction equipment,
and spontaneous combustion)

The major atmospheric contaminants associated with vehicular emissions and
spontaneous combustion are nitrogen oxides, sulfur oxides, hydrocarbons,
and carbon monoxide. The main concern with regard to these pollutants are
their effects on human health, flora, and fauna. Most of the information
on the effects of these pollutants are derived from toxilogical and
epidemiological studies of human and wildlife populations.

These pollutants affect primarily the lower respiratory tract, by
irritating the respiratory passageways and other muscosal tissues with
which they come in contact. (Dvorak, et al, 1978) Animals with higher
rates of ventillation or more exposed mucosal tissues relative to their
body size would be more sensitive to exposure than others.

G-5

Native plant species tend to be more tolerant of these pollutants than
crop or ornamental species. (Dvorak et al, 1978) These pollutants enter
the plant primarily through the leaf stomata and pass into the
intercellular spaces of the mesophyll, where it is absorbed on the moist
cell walls. If concentrations become toxic, damage will occur as a result
of chlorophyll destruction and cell collapse. (Dvorak et al, 1978)

Coal Dust - (generated by unit train transport, truck transport, vessel
transport, coal handling, stockpiling)

The effects of Coal Dust in the atmosphere may be a major consideration in
certain localities. Coal dust may reduce the air quality by releasing
volatile substances to the atmosphere. Coal dust may deposit on
vegetation plugging the stomates of leaves, lowering photosynthetic
activity and causing leaf necrosis. (Dvorak, et al, 1978) Long term
exposure to coal dust may cause changes in vegetation community structure.
Also, coal dust may cause some cleaning problems for people living-
nearby, as well as contributing to general aesthetic degradation of an
area.

0 Fugitive Dust - (generated by truck transport, train transport,
construction)

Fugitive dust from roads may also present some atmospheric problems, but
the effects will normally be a matter of aesthetic impact rather than
biological impact. However, fugitive dust from roads and land cleared for
construction can fall on plant leaves, reducing transpiration through
stomata, and decreasing photosynthetic capabilities of the plant. (Szabo,
1978) Fugitive dust including windblown coal dust is subject to the
federal standards for air quality.

EFFECTS ON ANIMAL AND PLANT COMMUNITIES

The major effects associated with the transportation and handling of
coal to the terrestrial environment are:

� Removal or Change in Vegetation - (caused by; construction, stockpiling,
and train and truck operation)

Removal of vegetation causes various impacts on the environment. it
destroys wildlife habitat and brings about the potential for erosion by
water and wind. (Missouri River Basin Commission, 1979) Removal of
vegetation may also cause some microclimate changes by altering humidity
levels, surface heating patterns, and wind fields. (Szabo, 1978)

� Reduction or Change in Animal Populations - (caused by; construction,
transportation, coal handling, and stockpiling)

The establishment of a coal unloading/ transshipment facility initially
results in losses of wildlife habitat from the site. However, the return
of fauna to available habitat should increase rapidly following completion
of construction. (Dvorak et al, 1978)

G-6

Mobile animal species will seek habitat in areas adjacent to the site, but
since these undisturbed areas are generally at their carrying capacity,
the total number of individuals of a given species will probably be
reduced. (Dvorak et al, 1978)

Generally human activity at the site will cause temporary disruption of
existing patterns of visitation by species. Most construction sites are
already surrounded by habitat adapted to intrusion, so the temporary
disruption caused by construction will have minimal adverse effect on the
foraging success of the animals. (Dvorak et al, 1978)

Noise Effects - (caused by; transportation, construction, dredging, coal
handling, and stockpiling)

The effects of coal related activities on noise levels of the surrounding
area may be significant and should be taken into consideration.

From a community standpoint, noise from the coal unload ing/transshipment
facility may be undesirable. For local residents, noise may seriously
disturb sleep by interrupting dreaming sequences. Sudden noises can
increase body tension, adversely affecting blood pressure, heart rate, and
the whole nervous system. Even noises that do not disturb normal hearing
can be emotionally upsetting. (Porteous, 1977)

Noise may also have adverse impacts on local wildlife, possibly disrupting
breading, nesting, and feeding activities of certain species. Noise
generated during loading/unloading and handling operations may affect
wildlife in the immediate vicinity. The effects of noise on wildlife can
be both auditory (hearing loss) or non-auditory (stress related). (Dvorak
et al, 1978)

Noise can also be expected to interfere with animal behavior of species
relying on auditory stimuli for communication. Excess noise levels within
100 meters of the facility may disrupt the normal nesting behavior of
passerine birds. Territorial and defense mechanisms may also be adversely
affected by excess noise. (Dvorak et al 1978)

The effects of intermittent noise on animals are less severe than the
effects of continuous noise.

AESTHETIC EFFECTS

0 Much which will occur during the construction and operation of a coal
unloading/transshipment facility may be considered an aesthetic impact.
Perhaps the most significant impact might be the reaction of people to
changes in the visual nature and character of the site. (Roy F. Weston,
Inc. 1974) Aesthetic appreciation is very subjective, and clearly varies
between cultures. The value of attitude, perception, and preference
studies becomes evident when dealing with industry official, designer, and
general public relationships.

G-7

Strong feelings against a proposed or existing facility will often be
voiced and can be considered aesthetic disapproval. The degree of
aesthetic disapproval will vary from individual to individual and the
significance of the aesthetic impact will be dependent upon the attitudes
of the people of the area toward the proposed or existing facility.
(Corps of Engineers, 1974)

G-8

TABLE G-1
COAL UNLOADING

ACTIVITIES

MODE OF MOVEMENT OF COAL POSITIONING VEHICLES ON SITE MOVEMENT OF POSITIONING OF COAL RELOADING OF COAL FOR
TRANSPORT THROUGH COASTAL ZONE FOR UNLOADING UNLOADING COAT, COAL TO STORAGEMSE AREAS FOR STORAGE LOCAL DISTRIBUTION

RAIL Unit Train on Rail Line Train on site next Rotary Car Dump Hopper to conveyor to Conveyor to radial. Rotary feeder to
100 ton payload per car to unloading equipment transfer house; to stacker put into loading station to
length may extend crushers or stockpile place by bulldozers loadout chute
beyond site

WATER Vessel or Barge Vessel in dock next Ship unloader Receiving bin to con- Conveyor to radial. Rotary feeder to
to unloading equip- a) on board veyor to transfer house; stacker put Into surge bin to
ment b) on shore to crushers or stockpile place by bulldozers shiploader

TRUCK 30 to 200 ton payload Truck on site next Unloading bin Rotary feeder to conveyor Conveyor to radial Rotary feeder to
to unloading equip- to transfer house; to stacker put Into surge bin to ship-
ment crushers or stockpile place by bulldozers loader

TABLE G-2

COAL TRANSSHIPMENT

ACTIVITIES

MOVEMENT OF COAL FROM POSITIONING VEHICLES MOVEMENT OF COAT,
MODE OF TRANSPORT SITE TO TRANSFER FACILITY FOR UNLOADING UNLOADING COAT, TO STORAGE AREA RELOADTNG COAL

RAIL Unit Train on Rail line Train on site next Rotary Car Dump Hopper to Conveyor to ---
100 ton payload per car to unloading equip- radial stacker; put into
ment; length may place by bulldozers
extend beyond site

WATER Vessel or Barge Vessel in dock next Ship unloader Receiving bin to Rotary feeder to surge
to unloading equip- a) onboard conveyor to radial bin to shiploader
ment b) onshore stacker; put into place
by bulldozers

TRUCK 20 to 200 ton payload Truck on site next Unloading Bin Rotary feeder to conveyor ---
to unloading to radial stacker; put into
equipment place by bulldozers

TABLE G-3

FACILITY OPERATION

ACTIVITIES

TRANSFER TO
MODE OF TRANSPORT UNLOADING OF COAL CONVEYOR BELT ON SITE USE TRANSFER TO STOCKPILE RELOADING OF COAL DUST CONTROI, LOCATTONS

RAIL Rotary Car Dump Rotary Car Dump Conveyor to Conveyor to Stockpile to a) Rotary Car Dump-dust controlled
(Unit Train) Hopper to a) transfer radial stacker/tele- a) rotary feeder with bag house collector
Conveyor house to scopic chute to b) loading station b) Conveyor system enclosed
b) conveyor stockpile c) loadout chute c) Transfer points-duqt controlled
to with sprays or bag hoiise collectors
crusher d) Radial stacker-dust controlled with
bag house collector or sprays
e) Stockpile-dust controlled by
spraying

WATER Ship Unloader Ship unloader Conveyor to Conveyor to Stockpile to a) Ship unloader-dust controtlpd with
(Vessel) a) on board to receiving a) transfer Radial stacker/tele- a) rotary feeder sprays
11011se to scopic chute to b) surge bin b) Conveyor system enclosed
b) conveyor to stockpile c) ship loader c) Transfer points-dust controlled with
c) crusher sprays or bag house collectors
d) Stockpil-e-dust controlled by
spraying

0 TRUCK Unloading Bin Unloading bin Conveyor to Conveyor to Stockpile to a) Bottom of unloading bin diist
I to rotary feeder a) transfer radial stacker/tele- a) rotary feeder controlled with sprays or bag
F1
0 to conveyor house to scopic chute. to b) loading station house collectors
b) conveyor to stockpile c) loadout chute b) Conveyor system enclosed
c) crusher c) Transfer points-dust controlled
with sprays or bag house collectors
d) Radial. stacker-dust controlled with
bag house collector or sprays
e) Stockpile-dust controlled by
spraying

TABLE G-4

STOCKPILING

ACIIV1TIES

MOVEMENT OF MOVEMENT OF COAL
SITE PREPARATION COAL TO PILE GROOMING/COMPACTTNC DUST SUPPRESSION RECLAIMING BERMING FROM PILE

Vehicles a) Bulldozer a) Conveyor a) Bulldozers a) Dozer equiped a) Bulldozers a) Bulldozers a) Front-end loader
and b) Front-end b) Receiving bin b) Front-end loader sprayer-, b) Front-end b) Front-end h) Hopper
Equipment loader c) Radial stacker/ b) Hoses loader loader c) Conveyor belt
c) Grader telescopic
chute

TABLE G-5

FACILITY CONSTRUCTION

ACTIVITIES-.

LAYING ACCESS MATERIALS DELIVERY
LAND CLEARING GRADING ROADS & SPUR LINES & STORAGE CONSTRUCTION SITE CLEAN-UP LANDSCAPE REHABILITATION

VEHICLES a) Bulldozers a) Bulldozers a) Graders a) Trucks a) Cranes a) Trucks a) Bulldozers
AND b) Front-end b) Front-end b) Bulldozers b) Trains b) Bulldozers b) Trains b) Front-end loaders
EQUIPMENT loaders loaders c) Front-end c) Bulldozers c) Front-end c) Bulldozers c) Graders
c) Graders loaders d) Front-end loaders d) Front-end d) Trucks
loaders d) Trucks loaders e) Trains
e) Trains
f) Fork lifts
g) Cement
mixers

APPENDIX H

COMPREHENSIVE MITIGATION STRATEGY

After environmental and socio-economic effects related to coal
movement and storage in the coastal zone have been identified and evaluated, a
comprehensive mitigation strategy may be necessary to help ameliorate
anticipated adverse effects. The mitigation strategy is an idealized approach
to addressing effects associated with coal unload ing/transshipment facilities,
because it can often be implemented without changes in present policies and
regulations.

Presented here is a strategy for the most extreme case, a case where
all possible effects will be encountered and must be dealt with. Specific
projects will not evidence all anticipated effects; each situation will be
different. In some cases, the effects will be insignificant and no action
will be needed, so not all the elements of the mitigation strategy may be
required. Further, since this is a generic study and very little information
on mitigation costs has been published, no attempt is made to suggest which
measures would be most cost-effective. This will vary by location, type and
scale of the proposed facility.

Some of these mitigation techniques may be important enough to be
incorporated into project proposals. This may or may not require changes in
regulation or legislation depending on the situation. This comprehensive
mitigation strategy delineates possible ways to ameliorate adverse effects in
the following areas of concern:

(A) Vessel Operation
(B) Dredging
(C) Dredge Material Disposal
(D) Construction
(E) On-Site Handling Coal
(F) Storage of Coal
(G) Transportation
(H) Economic Growth
(I) Employment
0) Housing
(K) Local Government Administration

(A) Mitigation Techniques for Vessel Operation Impacts

(1) Movement Impacts

� Establishment and enforcement of speed limits can assist in
reducing shore erosion, resuspension problems, and ri-sk to
structural damage resulting from effects of waves and/or collisions
with vessels.

� Modification of channels is often used as a technique to reduce
ship induced shoreline losses. Modification of channels may
present an economically justifiable technique for reducing movement

H-1

effects. However, modification of channels may also aggrevate ship
movement impacts depending on local conditions and the nature of
the project.

e The selective use of dredged material might help to dissipate some
of the energy of passing vessels, via small subsurface features.
Selective placement of dredged material also may help to limit near
shore sediment transport and release into the channel.

e Shoreline Protection - A number of shoreline protection methods
have been used to help alleviate ship-induced shoreline effects,
the major ones are:

(a) Gabion Shoreline Protection - Gabions are wire baskets filled
with rocks and wired together to form a wall or a lining.
Gabions are stable on steep slopes. They have low maintenance
requirements and a long life in the absence of destructive
forces.

There are some disadvantages to gabions as well. Gabion tear
resistance may not be high enough to withstand heavy i.ce
movement during the spring ice break-up. Also they can be
expensive to install.

(b) Rip-Rap Shoreline Protection - Rip-rapping involves the
realignment of shoreline by selective filling and armament
with stone or concrete. Where proper shoreline conditions
exist, rip-rap is an economical way of checking shoreline
erosion. It also provides good wave energy dissipation.

However, rip-rap needs a shelf to rest on and in many areas
the existing shoreline slopes are too steep to place rip-rap
upon. Also, the maintenance requirements of rip-rap
protection are very high.

(c) Sheet Pile Shore Protection - Anchored bulkheads constructed
of flexible steel sheet piles restrained by tiebacks are often
used to protect a shoreline. They have a long expected life,
have small maintenance requirements, are aesthetically
consistent, and provide recreational access for fishing and
boating.

The major drawback of anchored bulkheads is the high cost for
materials and installation.

(d) Vegetation - Establishment of vegetative plantings is often
the most inexpensive, effective and environmentally sound
technique for protection of shoreline. The major drawback to
vegetative stabilization can be difficulty of establishing and
retaining vegetative cover.

(2) Discharge Impacts

e Pumping noxious bilge waste into onshore recepticles, as required
by law will eliminate discharge impacts.

H-2

0 Separating noxious from nonnoxious bilge waste prior to pumping of
bilge, can reduce the effects of overboard discharge.

(B) Mitigation Techniques for Dredging

� Schedule dredging operations to avoid environmental impacts during
periods which appear to be susceptible to stress (i.e. fish
spawning seasons)

� Scheduling dredging operations to avoid recreational impacts. For
instance, dredging in the fall when recreational boating activities
have subsided below summer levels.

� Simple equipment maintenance and efficient operation can improve
the sediment removal efficiency and reduce turbidity in surrounding
waters.

� Develop guidelines for use of floating turbidity curtains (diapers)
to help reduce turbidity. Turbidity curtains are effective in
still water, but will be ineffective in areas where currents exceed
I knot.

� Use of a different type of dredge, (mechanical or
suction-mechanical) can at times reduce overall turbidity.

� Specific on-site evaluations should be made on a case-by-case
basis, taking into consideration all of the environmental impacts
(physical, chemical, and biological).

� Bucket dredges, hopper dredge, bottom-dump scows, and pipelines
should be well maintained to reduce material losses.

� Operating practices and maintenance standards for delivery
machinery should be established to ameliorate potential impacts.

� Evaluation of dredged material disposal options - all practical
alternatives to the discharge of materials to the waters of the
Great Lakes should be considered.

� If a confined disposal site is to be constructed it must be
designed, built, and operated in such a way as to achieve maximum
effective capacity and satisfactory effluent quality. For example,
surface trenching has proved to be a cheap and effective way of
providing natural drainage.

� The regulated discharge of disposal area effluent through a natural
marsh can be effective in removing nutrients.

� Dredge material (particularly dewatered dredge material) has value
for land filling or in construction. Use of dredge material for
road construction and dike raising should not be overlooked when
considering alternatives.

H-3

e Wetland vegetation, soils, and hydrology should not be altered by
dredging or filling in order to insure that the water retention,
and ecologically productive functions of the wetlands will not be
diminished.

e Dredge spoils can be treated with flocculents to reduce the time it
takes for sediments to settle. This treatment also will minimize
the release of pollutants absorbed by the sediments.

For a site specific review of dredge disposal operations the following
elements should be looked at.

e Evaluate existing information - an overview of past dredging and
disposal activi'ties, sediment quality history, and known
environmental sensitivities of the area should be of assistance in
identifying disposal options.

* Physical characterization of sediments - the physical
characteristics of a sediment provide an identification of the
potential for chemical contamination and assist in the
identification of possible uses of the dredged material. (i.e.
beach nourishment).

o Chemical characterization of sediments - the chemical
characteristics of the sediment when compared to open lake bottom
conditions provide a relative indication of sediment quality, and
the potential for the dredged material to degrade the substrate at
an open lake disposal site.

0 Bioassessment of sediments - to determine the effects of dredging
and dredge disposal on biota. This would involve exposure of
specified aquatic organisms to sediments and measuring lethal
(acute toxicity) and sublethal (reproductive impairment) responses.

(D) Mitigation Techniques for Construction Related Impacts

� Dust control implementation. Spray critical construction areas and
temporary roadways to help keep dust levels low.

� Carefully manipulate drainage from the site. Use of impoundments
will help remove suspended solids introduced by erosion from
construction areas.

� Construction impact on vegetation and associated wildlife will be
minimized by proper selection of construction areas, replanting
selected trees, and by new planting of native plant species
affected by construction.

� Rapid stabilization of disturbed areas will help reduce dust and
erosion problems . For instance , the disturbance caused by
construction of a proposed coal facility could be rectified by
sodding, or by importing topsoil and reseeding (fast cover crop
such as rye grass) . Such action would reduce the environmental
impact of construction and would serve to stabilize the soil.

H-4

Also, trees could be planted to restore the attractiveness of the
area.

� Transplanting trees from construction areas to other areas will
help screen the area by reducing dust and noise. Also, limiting
off-road vehicular traffic will help prevent needless destruction
of vegetation in non-construction areas.

� Locating the structures in areas where vegetation is in early or
mid-successional stages (fields and young wood-lots) will help
hasten the natural revegetation process.

� Reduce the area for equipment laydown and access roads to lessen
the impact on wildlife.

� Actively manage the area for wildlife. For instance, stationary
equipment can create increased roosting and nesting sites for
gulls, pigeons, and swallows.

� Reclaiming disturbed areas with wildlife in mind. Planting food
plants, establishing water holes, and creating nesting sites will
help keep wildlife in the area.

� Sound levels during construction activities should be monitored to
determine the effects of noise from construction activities, and to
identify and control noise from those activities which may
significantly affect sound levels.

Mitigation Techniques for On-Site Handling Related Impacts

� Receiving Bins - receiving bins should be designed with a
semicircular backstop to help prevent coal spillage from the bin
into the waterway, and to help prevent the wind from blowing coal
dust out of the bin.

� Conveyor System - the main conveyors should be completely enclosed
to reduce dust being blown into the atmosphere. Also, conveyor to
conveyor transfer points should be enclosed. Any dust generated
during transfer will be ventillated to baghouse dust collectors.

� Unloading Bins - Emissions should be controlled at the bottom with
sprays or a dust collector with bags. Scrubbers are sometimes
used. Enclosure of the bin on three sides and with a sloping roof
will contain the dust in many cases. If supplemental control is
required, curtains can be hung to partially close the opening when
a truck is dumping. A dust collector (baghouse collector) can then
be used. Sprays do not function well at bin locations because the
areas are large and the dust generation is violent and intermittent.

� Loading Stations -use of a loadout chute can prevent large amounts
of dust and spillage when coal is transferred to cars in high
volumes. The chute is a large, vertical, telescopic device that
travels to the car bottom with each car, raises with the coal as
the car is loaded, stops and crowns the car, stops the flow of coal

H-5

as cars are changed, and repeats the cycle. This helps prevent the
escape of dust because the chute remains in contact with the coal
in each car during loading.

� Rotary Car Dump - to mitigate impacts from the rotary car dump, the
operation should be enclosed in a building, and dust emissions
should be ventillated to baghouse collectors.

� Stacker/Reclaimer - fugitive dust emissions generated during the
stacking and reclaiming operations should be ventillated to a
baghouse collector or controlled by spraying.

� Dust Control System - the major dust control solution should be
through spraying, and should be applied through spray headers at
four transfer points where dust generation is most likely to occur.
These are: (a) the top of the receiving bin, (b) receiving bin to
conveyor, (c) conveyor to radial stacker, (d) head pulley radial
stacker (transfer house).

� Noise - sound levels during facility operation should be measured
and documented to insure that State, Federal, or local guidelines
have been met.

� Vegetation - precautions designed to minimize spillage of coal will
assist in minimizing adverse effects on vegetation.

(F) Mitigation Techniques for Storage Related Impacts

Methods for control of dust from coal storage piles are limited in
effect or are very expensive. However, there are a number of methods that
will at least partially alleviate the impact of dust from a coal storage pile.

� As a minimum, coal piles should be capped with larger sized coal to
prevent the loss of fines due to wind.

� Bituminous coal should be tightly packed to prevent fires
(spontaneous combustion).

� Some installations use concrete silos, which hold up to 10,000 tons
and control dust effectively.

� An earthen impoundment can help to contain and control coal dust
from a coal pile.

� All semi-permanent storage capacity should be established on the
periphery of the storage pile. The exterior face should then be
treated for aesthetic considerations. The peripheral reserve
storage will act as a windbreak completely surrounding the storage
pile .

� The effects of grooming of the coal pile by large bulldozers should
be closely examined. All dozers should be equipped with wet
suppression systems.

H-6

� The design of the fans on bulldozers should be changed to minimize
the blowing of coal dust into the air.

� Spraying techniques should be used on all active portions of the
pile . A major portion of these particulates can be controlled by
water sprays.

� Settling basins should be used to mitigate the adverse impacts of
runoff.

(G) Mitigation Techniques for Transportation Related Impacts

(1) General

9 For controlling wind losses of coal dust, wind guards (30 cm high)
are partially effective for uncovered trucks or rail cars.

* Coal should be wet down before transport. Washed coal retains much
of its moisture, which aids in reducing wind losses.

o Sealing the surface of each load of coal with a latex-polymer or an
asphalt emulsion has been effective in reducing wind losses. Also
dustproofing the coal with oil or calcium chloride is a common
practice. Application of dust suppressants is most efficient while
the coal is in the air, as during loading. The use of properly
designed hoods will help prevent waste of the dustproofing
materials.

o Organic sealants help reduce wind losses but not spillage. Proper
covering is the only way to contain the coal totally during transit.

o Revegetation of reclaimed areas should be done as soon as possible.

(2) Rail

� Mufflers on the exhause system can greatly reduce the noise from
diesel locomotives. In addition, modified casing with acoustical
absorbent material around the engine can successfully reduce
overall engin.e noise. The use of continuous welded rail can
achieve noise reductions greater than 5 decibels. It may be
possible to incorporate this type of rail for use in urban areas.
Otherwise, proper maintenance of the rail and bed will keep noise
from this source sufficiently.

� Locomotives should be equipped with the latest designs in spark
retention arrestors and non-sparking brake shoes. Control of fires
will reduct the amount of wildlife habitat and vegetation destroyed
by rail transport.

� Chemicals are used on rights-of-way to control the growth of
vegetation for both safety and aesthetic reasons. Control of weeds
and brush improves visibility, reduces fire hazards, and provides

H-7

for a safer working enviornment. The chemicals that are used,
should be effective in controlling vegetation, but also nontoxic
and nonpersistent.

9 Abandonment - a few abandoned rail beds have been turned over to
the public as paths for hiking or bicycling, where this cannot be
done the right-of-way is often graded and revegetated to encourage
reestablishment of native flora and fauna

(3) Truck

� During construction of the roads, topsoil should be saved and banks
seeded. Culverts will be needed wherever the road crosses natural
surface drainage channels. Settling basins (sediment traps) should
be constructed downstream from the culvert crossing, the collect
material that may wash from the haul road.

� Watering the roads throughout the work day with truck mounted spray
equipment will help reduce wind blown dust.

� Better designed trucks with covered aluminum bodies would help
reduce wind loss and spillage. Spillage and dust will remain a
problem with older uncovered trucks. One solution would be to use
removable tarpaulin covers.

� Noise reduction - emphasis should be placed on reducing noise at
the source rather than on the use of shields or covers as secondary
noise - reduction devises. However, enging covers and pannels have
proved to be the most successful short-term approach to reducing
noise.

� Mufflers have been effective in reducing noise levels. and research
on new types of mufflers is being conducted in an effort to reduct
noise even further. Possible innovations include placing a
resonator close to the exhaust manifold, exhaust pipe wraps, and
double wall or laminated exhaust pipes.

� Road damage - forbid operations of coal trucks on roads not
designed for their use. Assess a tonnage tax for use of country
roads. Put an export tax on coal.

� Assess a ton/mile tax specifically for the coal handler. More
permanent haul and access roads should be paved to reduce dust.

� Abandomment - abandoned roads must be reclaimed in a manner that
will minimize erosion and encourage the reestablishment of native
vegetation and wildlife habitat. Reclamation includes shaping the
roadway, adding topsoil as needed, and seeding the surface.

(4) Community Effects

e With regard to the nuisance aspect of truck transportation, public
education about the role of coal in the local economy and their
well-being can minimize the degree of inconvenience felt by the
public.

H-8

� Public safety can be enhanced by posting signs indicating which
roads are haul routes, cautioning the public to heavy traffic.

* Delivery and dispersal of traffic to and from the transshipment
facility can be improved by constructing a new highway interchange
which is usually connected with the interstate highway system.
This measure would reduce the level of community' disruption by
routing traffic through the outskirts of the community.

� An additional travel lane can be used at key locations to reduce
traffic congestion during peak traffic hours. This can be
accomplished by constructing a new lane, or through the reversible
land concept. The latter method varies the number of usable travel
lands in each direction according to demand (e.g., morning rush
hour--three lanes inbound, one outbound). This method is less
expensive to build and maintain than additional traffic lanes.

� Communities anticipating increased rail shipment of coal should
evaluate the existing rail infrastructure and provide adequate
warning equipment at crossings. Switching operations should be
updated to eliminate unnecessary delays at crossings that have no
trains approaching.

� To the extent feasible, the community should attempt to acqui.re
scheduling commitments with the railroads in order to establish a
predictable ro consistent train schedule.

� Railyards and transshipment facilities should incorporate a buffer
zone using natural vegetation to reduce adverse aesthetic effects.

� Alternative emergency routes should be planned for communities
interrupted by frequent train transportation. The affected
community should look into the possibility of using the emergency
services of neighboring communities when delays at crossings
threaten emergency service delivery.

� When feasible, new rail lines or spur lines should be routed
through the outskirts of the community to avoid community
disruption.

(H) Mitigation Techniques for Encouraging Desired Economic Growth

� Local governments could work together to encourage growth in areas
beneficial to the area as a whole. Increased public revenue could
be directed to that end. Industrial parks, downtown renewal, and
residential street construction are all activities that could
encourage development in desirable areas. Strong land use controls
and agricultural loan programs could retain existing land use where
it is desired by threatened.
I
� In cases where required community investments overwhelm local
revenues, local governments may wish to consider tax based sharing
in the personal, property, and utility classifications, with other
communities, or assistance under the Coastal Energy Impact Program.

H-9

(1) Mitigation Techniques for Encouraging Employment

� Manpower programs should be organized or expanded to provide
technical and practical training for local residents in the areas
where labor shortages are expected.

� When economically and practically feasible, phased construction
should be instituted to reduce the problems associated with
dramatic employment fluctuations.

� Job openings should be advertised locally prior to start-up.

� During the process of evaluating a new transshipment or unloading
facility proposal efforts should be made to establish a target
level of desired local employment and to identify requirements for
non-local labor force.

(J) Mitigation Techniques for Reducing Housing Fluctuations

� Housing relocation problems for in-migrating workers can be
minimized by increasing the construction worker's knowledge of
available housing. Information on housing can be disturbed to
workers through the construction company office or at the
construction site. Housing assistance services can be coordinated
through the area Board of Realtors.

� The progress of the construction and the state of the housing
market should be closely monitored by local planning and community
development agencies so that changes in variables such as the size
of the construction force, the local/nonlocal workforce
composition, the number of in-migrating families, etc., can be
accomodated.

� The area planning commission and housing referral services should
coordinate efforts to provide housing assistance to low income and
fixed income families.

(K) Mitigation Techniques for Asssisting Local Government Administration

Revenues from existing tax structures generally do not cover the
costs of furnishing necessary services in a timely manner. Options to
generate funds include:

� Advance payments of future taxes, however these may not be readily
repayable bby the municipalities in the future.

� New taxes or state legislation relating revenue transfers to
community patters.

� Subsidies from commercial companies or real estate developers.

H-10

Federal subisdies in the form of special revenue sharing, or funds
appropriated to facility development for energy sources. In
particular, coastal energy impact program funds might be used to
help communities plan for meeting demands resulting from
construction and operation of a coal unloading or transshipment
facility.

H-11

APPENDIX I

REVIEW OF MICHIGAN AND FEDERAL POLICIES

INTRODUCTION

This appendix reviews Michigan and Federal policies applicable to the
demand for, transportation of, and construction of facilities to transport
coal. Each policy area contains an overview of major legislation and programs
and an evaluation of the effectiveness or actual impact of these policies on
coal transshipment related issues. A summary table (Table I-1) at the
beginning of this appendix lists all major legislation, its legal citation,
and a short description of each piece of legislation.

TABLE I-1

MAJOR LEGISLATION APPLICABLE TO COAL SUPPLY AND DEMAND,
TRANSPORTATION, HANDLING, AND FACILITY DEVELOPMENT

FEDERAL LEGISLATION
(*Discussed in greater depth in following sections)

Legislation Brief Description

� *Energy Supply and Environmental * First Federal attempt at legislating
Coordination Act of 1974 P.L. 93-139 coal conversion of powerplants and
major fuel burning installations.

� *Powerplant and Industrial Fuel Use * Expanded provisions of ESECA, placed
Act of 1978 P.L. 95-620 the burden of proving inability to
comply on facility owner.

� *Federal Coal Leasing Amendments Act e Sought to discourage speculation by
of 1975 P.L. 94-377 making it more difficult to obtain
and cheaply hold leases to coal
lands.

� Energy Reorganization Act of 1974 6 ERDA required to ensure the
P.L. 93-438 environmental acceptability of the
energy technologies under
development .

� *Energy Tax Act of 1978 P.L. 95-618 9 Most importantly, contains provisions
concerning tax credits, possibly
affecting coal demand

e.*Ports and Waterways Safety Act of * Attempts to prevent damage to
1972 P.L. 92-340 structures in, on, or immediately
adjacent to the navigable waters of
the United States or the resources
within these waters.

� *Noise Control Act of 1972 P.L. 92-574 e To protect health and welfare ambient
noise levels are recommended; they
may become standards for facilities
regulated by state and local
governments.

� *Railroad Revitalization and Mandates the establishment of a rail
Regulatory Reform Act of 1976 P.L. bank, consisting of rail track and
94-210 other properties, for the purpose of
preserving existing services in
certain areas of the U.S. in which
fossil fuels and other natural
resources are located.
1-2

Legislation Brief Description

� Local Rail Service Assistance Act of e Separate federal program for fossil
1978 P.L. 95-607 fuel movements eliminated. Federal
assistance funds can still be used to
acquire rights of way for the
preservation of existing and
development of further rail service.
Fossil fuel service is now only one
of the criteria used in determining
whether a state is to receive federal
funds for acquisition of subsidy.

� *Clean Air Act as Amended P.L. 91-604 * Ambient air quality standards have
as amended by been set for SO 29 TS03 NO 21 CO, HC,
P.L. 92-157 and 0x ; more are being considered.
P.L. 93-15
P.L. 93-319 e New Source Performance Standards
P.L. 95-95 (NSPS) apply to coal-fired boilers
and regulate SO NOx and
particulates. Lwer emission levels
are being considered, as are
regulations for small particulates.
Stricter standards specific to FBC
may be established.

9 Standards for hazardous air
pollutants regulate mercury,
beryllium, and asbestos.

e NSPS and regulations for the
prevention of significant
deterioration may affect plant
siting.

e Best Available Control Technology
(BACT) may be required when locating
in "clean" regions. BACT will be
determined on a case-by-case basis.

* Lowest Achievable Emission Rates
(LAER) may be required when locating
in non-attainment regions.+

� *Coastal Zone Management Act of 1972 a State coastal zone management plans
P.L. 92-583 as amended by P.L. 94-370 developed with federal financial
assistance may affect plant siting
and design.+

� *Marine Protection, Research and e Permits are required for activities
Sanctuaries Act of 1972 P.L. 92-532 in wetland areas, which may restrict
facility siting.+

1-3

Legislation Brief Description

� *Rivers and Harbors Act 33 U.S.C. @ Permits are required for dredge and
401-413 fill activities in navigable waters,
which may affect facilities siting.

* Projects must be integrated with
flood control, river, and dam
projects.+

� *Federal Water Pollution Control Act * National Pollutant Discharge
Amendments of 1972 P.L. 92-500 Elimination System (NPDES) permits
are required to control wastewater
discharges.

* Since effluent guidelines have not
been developed for most fossil energy
technologies, permit requirements are
determined on a case-by-case basis to
meet state plans.

* A "No Discharge" goal has been set
for 1985.+

e Significant non-point source water
pollution sources must be controlled
under Section 208 planning
provisions.

� *National Environmental Policy Act of 9 Environmental Impact Statements
1969 (NEPA) P.L. 91-190 (EIS's) must be prepared for all
major federal actions significantly
affecting the quality of the human
environment. Environmental Impact
Assessments (EIA's) usually done to
determine which actions require
EIS's.+

� Nonnuclear Energy Research and * Water availability assessments are
Development Act of 1974 (Section 13) required for commercial plants and
P.L. 93-577 demonstration plants which may have a
significant impact on water
availability. Assessments are done
by Water Resources Council (WRC).+

� Resource Conservation and Recovery e Solid waste disposal must comply with
Act of 1976 P.L. 89-272 most stringent air and water
standards; monitoring is required.

a New regulations will be developed in
1-2 years for a federal hazardous
waste handling permit system and
state programs for non-hazardous
solid wastes.+

1-4

Legislati on Brief Description

� National Historic Preservation Act of a Federally financed, assisted, or
1966 P.L. 89-665 permitted projects cannot impact
important historic or cultural sites
unless no alternatives exist.+

� Endangered Species Act P.L. 93-205 9 Identification of endangered aquatic
and terrestrial species at a
potential construction site is
required, which may affect facility
sLting.+

� *Fish and Wildlife Coordination Act o Any project requiring modification of
P.L. 85-624 bodies of water must be reviewed to
prevent loss or damage to fish and
wildlife.+

� Wild and Scenic Rivers Act P.L. 9 Projects may not degrade the quality
90-542 of wild and scenic rivers.+

NOTE:

+ indicates that the description of the legislation presented was provided by:

Environmental Development Plan (EDP)
Coal Gassification Program (March, 1978)
Direct Combustion Program (March, 1978)
Coal Liquefaction Program (March, 1978)
U.S. Department of Energy

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STATE LEGISLATION
(all discussed in greater depth in the following sections)

U-egislation Brief Des-cription

� Michigan Vehicle Code P.A. 300 of e Regulations evolved pursuant to this
1949 as amended by House Bill 5675 of act related to truck weight
1980 (act number assignment pending) restrictions.

� Vehicle Noise Control Act P.L. 300 of * Enacts state noise standards
1949 as amended by Acts 73 and 492 of identical to federal regulations,
1978 (Part of Michigan Vehicle Code) thereby broadening noise control
coverage.

� P.A. 198 of 1873 as amended by P.A. o Deals with regulation of the
239 of 1966 allowable duration of rail crossing
blockage.

� Michigan Environmental Protection Act * Provides litigation guidelines for
of 1970 P.A. 127 of 1970 cases dealing with the state's air,
water, and other natural resources;
and mandates the consideration of
environmental factors in
administrative decisionmaking.

� Soil Erosion and Sedimentation Act e Regulates, by permit, development
P.A. 347 of 1972 which involves earth changes in
certain areas.

� Great Lakes Submerged Lands Act P.A. e Regulates, by permit, the use,
247 of 1955 filling, or sale of submerged lands
wi-thin state boundaries.

� Inland Lakes and Streams Act P.A. 346 o Regulates, by permit, activities
of 1972 including the dredging or filling of
bottomland, placement of structures,
construction of artificial waterways,
and structural interference with the
natural flow of an inland lake or
stream.

� Geomaere-Anderson Wetland Protection 9 Regulates, by permit, alterations of
Act P.A. 203 of 1979 wetlands, including drainage of
surface water, construction, dredging
and filling.

(THE PRECEDING THREE ACTS DIFFER PRIMARILY IN AREA OF APPLICABILITY)

1-6

Legislation Brief Description

� Shorelands Protection and Management e Regulates land uses and developments
Act P.A. 245 of 1970 within (1) environmental areas, (2)
areas prone to high risk erosion, (3)
areas within the 100-year floodplain.

� Natural River Act P.A. 321 of 1970 9 Provides for designation as Natural
River Area for the purpose of
preserving historic, aesthetic,
ecological, and recreational values.

e City and Village Zoning Act P.A. 207 9 Provides for the regulation and
of 1921 as amended most recently by restriction of land use and
P.A. 638 of 1978 structures by city or village
legislative bodies.

NOTE: Only state and federal legislation is included in these tables,
Discussion of other policies and programs are included in following
sections.

1-7

ENERGY POLICY AND COAL

As coal demand in the Great Lakes region will clearly be one of the
most important determinants of future movement levels, recent United States
energy policy may exert considerable influence on coal transshipment in
Michigan's coastal zone. Policy approaches, such as legislating coal
conversions in utility and industrial boilers, are direct inducements to coal
demand increases. Less direct approaches, such as legislation dealing with
coal lands leasing or curtailments and taxes affecting the desirablility of
other fuels relative to coal, also may affect coal demian. This section
identifies and evaluates both legislation for direct coal conversion and
policy related to coal demand in a less direct way.

COAL CONVERSION LEGISLATION

The Energy Supply and Environmental Coordination Act of 1974

The Energy Supply and Environmental Coordination Act of 1974 was the
f irst federal administration of a coal conversion program (P.L. 93-139).
Under this act the Federal Energy Administrator was authorized to prohibit any
power plant or major fuel burning installation from burning natural gas or
petroleum products as its primary energy source if he/she determined that the
installation had the capability and necessary plant equipment to burn coal
(Section 2, Subsection [a]). Prohibitions of this type could only be made
pursuant to the requirements of subsection (b) which included;

� that coal and coal transportation facilities would be available
while the order is in effect (subsection [b][11)

� that service reliability would not be impaired (subsection [b][11)

� that environmental regulations did not preclude coal use
9(subsection [b][21).

The.Act also empowered the Federal Energy Administrator to require
any power plant in the early planning stage to be designed and constructed so
as to be capable of using coal as its primary energy source unless this would
result in an impairment of service or an adequate supply of coal was not
expected to be available. Consideration was also to be given to the ability
of the owner to recover any investment made as a result of a requirement
imposed under this subsection (subsection (0).

Amendments to Title I of the Clean Air Act were also contained within
the Energy Supply and Environmental Coordination Act (Section 3). Most
importantly, this section outlines the procedure for issuing emission
standards compliance date extensions for facilities which were prohibited from
using petroleum products or natural gas by an order from the Energy
Administrator under section 2 of the ESECA. This provision allows a grace
period for the owner of a facility being forced to convert to coal to obtain
and install any necessary equipment needed to comply with emission standards,
though he/she must somehow comply with all primary standards during the
extension period (e.g., by adjusting level of production). Finally, the Clean
Air Act was further amended by requiring the Administrator of the

1-8

Environmental Protection Agency to review each state's implementation plan and
report to the states on whether the plans should be revised in light of coal
conversion orders (Section 4).

The Powerplant and Industrial Fuel Use Act of 1978

The federal coal conversion program which ws initiated under the
Energy Supply and Environmental Coordination Act was modified and expanded by
the Powerplant and Industrial Fuel Use Act of 1978 (P.L. 95-620). Provisions
of this act include:

0 prohibition against use of oil or natural gas in new electric
facilities or in new industrial boilers without DOE exemption
(Section 201).

0 restrictions requiring existing coal capable facilities to use
coal and to require non-coal capable units to use coal-oil
mixtures (Section 301).

0 limitation of natural gas use by existing utility powerplants to
the proportion of total fuel used during 1974-1976, and a
requirement that there by no switches from oil to gas. Complete
ban on gas in these facilities by 1990 (Section 401).

Under this law, new facilities may not legally burn oil or gas as a
primary energy source and existing facilities may not use natural gas after
1990. Exemptions are provided to facility operators who can demonstrate that
they cannot comply with oil or gas prohibitions due to:

environmental regulations

site-specific limitations, such as space for handling equipment
or waste disposal

� system reliabiity impairment

� the cost of using coal substantially exceeding the cost of using
imported oil. (Department of Energy, 1978).

Other provisions of this Act include temporary "public interest"
exemptions when using oil or natural gas serves the public interest and
allowances of oil and gas fired boilers, in some cases, in peak load
generating facilities (DOE, 1978).

Evaluation

The federal coal conversion program initiated in 1974 appears at
first glance to provide the tools necessary to dramatically increase coal use
and therefore demand, in the coming years. The effectiveness of the program
h'owever, is disputed within both the public and private sectors, and the level
of actual conversions occurring pursuant to the provisions of the Energy
Supply and Environmental Coordination Act of 1974 (ESECA) and/or the
Powerplant and Industrial Fuel Use Act (PIFUA) of 1978 does not appear to be
compatible with the energy goals of the Carter Administration.

1-9

With the exception of non-finalized conversion orders issued under
the ESECA, the Powerplant Act of 1978 has generally preempted all federal coal
conversion authority. The provisions of the PIFUA, intended to strenghten the
regulatory program under ESECA, have, however, been subject to numerous
temporary and permanent exceptions, and have not caused a notable increase in
actual conversion of previously non-coal burning utilities and industries.
Representatives of the National Coal Association, both in persorfal conversions
and in their Third Annual Report to the President, have indicated
dissatisfaciion with the current coal conversion policy of the federal
government. The association feels that exemptions from the PIFUA
requirements, such as those issued by the DOE subject to "the public
interest," are serving to permit the use of natural gas as a boiler fuel even
in cases where coal could be used. other impediments to coal conversion
identified by this group include air quality and other environmental
requirements and delays in granting government approvals for conversion.

The congress has also expressed concern that the PIFUA is not forcing
coal conversion at an acceptable rate. The proposed Powerplant Fuels
Conservation Act, in actuality an amendment to the PIFUA, would create several
provisions which are more forceful than those in past statutes. Though this
act has not yet become law, it would mandate the conversion of some eighty
powerplants and does not contain further pollution control measures, such as
those suggested as necessary to deal with acid rain problems. The proposed
amendments also would provide federa@ assistance to plants forced to convert
to financially aid in the conversion.

The consensus seems to be that, although current policy may be
increasing coal demand through regulation of new powerplant and industrial
boilers, the conversion of existing facilities is not being forced by federal
policy. The demand of coal, and therefore the amount of coal moved through
the Michigan coastal zone, will probably depend on the success of
strenghtening amendments to the PIFUA. Unless such amendments are passed, or
current legislation is made workable in some other way, the increase in coal
demand in this area may not be as large as has otherwise been projected.

I
'Personaf_j(Tn_tZct:
6/25/80 Counsel for Regulatory Affairs Office
National Coal Association
Washington, D.C.

Publication:

Increasing the Contribution of U.S. Coal In Supplying The Nations
Energy Requirements, Third Annual Report of the National Coal
Assocation, May 1980.
2Personal Contact:

Democratic Policy
Staff of Senator Robert Byrd
Washington, D.C.

1-10

OTHER ENERGY LEGISLATION

The Federal Coal Leasing Amendments Act of 1976

The Federal Coal Leasing Amendments Act (30 USC subsection 193(a))
was passed in 1976 to address. deficiences in the Mineral Leasing Act of 1920.
These amendments sought to discourage speculation by making it more difficult
to obtain and cheaply hold leases to coal lands (OTA, 1979). Consequently,
several of the provisions have the potential for affecting the availablity of
coal by imposing economic and environmental constraints on the coal mining
industry.

Provisions of the Act relating to obtaining and holding coal land
included:

0 that no less than fifty percent of all lands leased must be
leased under a system of deferred bonus payment, thereby making
it easier for small companies to compete (subsection 201(a)).

that bids for land shall not be accepted for less than the fair
market value of the coal subject to the lease (subsection
201(a)),

0 that leases must be developed within ten years of issuance or be
terminated (subsection 201(a)(2)(A)).

Sections containing what could be called "environemntal provisions"
were included, and sought to address both natural and social environmental
impacts. These included:

0 that comprehensive land use plans are to be developed by the
Secretary of the Interior, taking into consideration proposed
coal development in these lands (subsection 201(3)(A)(i)),

0 that environmental and community interests are examined and
considered in issuing exploration license and leases (subsection
291(a)(c) and 201(b)(l)-(4)), and

0 that each coal lease shall contain provisions requiring
compliance with the Federal Water Pollution Control Act
(subsection 201(a)(0).

Evaluation

The FCLA can be, and are, perceived in different ways by different
interst groups. Environmentalists may feel that these amendments protect
against detrimental aspects of activities such as strip or surface mining,
while coal industry representatives contacted during this study expressed
dissatisfaction with the Act. Coal mining company representatives, though
largely reluctant to comment on federal regulations, seem to generally agree
that fedIral leasing policy impedes coal land development on government
property. it should be noted, however, that many federally owned coal lands
are in the western part of the United States, and federal leasing constraints
may not significantly affect the levels of coal movement through the Great
Lakes basin unless western coal begins to play a larger role in the supply for
this region.

1. Specific company comments included:
� that the requirement for land development within ten years of
lease issuance is unrealistic due to the extensive administrative
processes which often must be contended with before development
can occur.

� that environmetnal requi-rements are often unrealistic and used by
certain interests to block coal land development.

� that Federal Water Pollution Control Act provisions require large
expenses in terms of time and money, and ' are sometimes
unnecessary, at least to the degree that they are often employed.

� that the current procedure used by the Interior Department for
determining "fair market value" of coal lands results in
unrealistically high minimum bids, and causes the bypassing of
some federal coal.

1-12

The Energy Tax Act of 1978 and The Natural Gas Policy Act of 1978

The Energy Tax Act and Natural Gas Policy Act, both parts of the
National Energy Act of 1978, contain provisions which may indirectly affect
the demand for coal by industrial users. By provisions which will alter the
economic desirability of coal relative to other fuels, conversion may be
encouraged. Specifically, the Energy Tax Act provides for Business Energy Tax
Credits (Section 391) and the Denial of Tax Benefits for New Oil and Gas Fired
Boilers (Section 301); while the Natural Gas Policy Act provides for the
deregulation of some natural gas (Section 121), incremental pricing of natural
gas (Section 301), and emergency authority for the President with respect to
natural gas allocation (Section 301).

The Energy Tax Act

A. Business Energy Tax Credits Section 301(a)-(c) provides business
tax credits tor industr al investment in alternative energy
equipment (coal boilers and other supplemental equipment would be
included)

B. Denial of Tax Benefits for New Oil and Gas Fired Boilers - Section
301(d)(2) denies investment tax credit for certain property
including boilers fueled by oil or gas unless coal use is
precluded by air pollution regulations. Denial of rapid
depreciation of boilers fueled by oil or gas is provided for in
Section 301(d)(3).

Both these provisiosn of the Energy Tax Act could provide
incentives to convert to coal while making expanded oil or gas
capacity financially undesirable with respect to tax credits.

The Natural Gas Policy Act

A. Deregulation of Some Natural Gas - Section 121 lifts price
controls on new natural gas and some interstate gas as of January
1985. All gas prices will not be deregulated; however, those that
are will undoubtedly go up, making natural gas a less attractive
fuel.

B. Incremental Pricing - This program, described in Section 201 of
the Act, endeavors to protect residential users of natural gas by
passing increased prices along to industrial u s e r s . The
incremental price of gas to industrial users would be the new
deregulated gas price plus transportation margins.

C. Emergency Authority - Under Section 301 of the Act, the President
may declare a natural gas supply emergency and may allocate
certain suplies of natural gas during such an emergency to "high
priority" users. The group of high priority users would include
those involved in maintaining health or physical property and
those of residential or small commercial nature. Under such
authority, the President may choose not to allocate gas for use in
certain gas boilers.

1-13

Evaluation

The Natural Gas Policy Act clearly contain implications for the
desirability of gas relative to other fuels such as coal. The deregulation of
gas prices, incremental pricing of future industrial purchases, and the
prospect of presidential curtailment of supplies for certain users may
contribute to a decreased industrial demand for gas, perhapS7 resulting in
increased coal demand.

The Energy Tax Act and Natural Gas Policy Act are both recognized as
potentially useful in increasing coal demand. The ETA is a useful framework
for providing coal conversion incentives and disincentives for gas or oil use,
however regulations have not yet been issued pursuent to the provisions to
this act . This fact has so far impeded the effects of the act, as which
organizations would qualify for benefits under this legislation remains
uncertain, and investments based on expected benefits remain tenuous.

The NGPA has somewhat increased the attractiveness of coal with
respect to other fuels. Gas however, is still being deregulated at a slower
rate than oil, and remains attractive in many sectors. Despite both this act
and the incentives of the Energy Tax Act, coal remains a demand-constrained
commodity. The long term effects of this legislation on coal demand in our
region still seem uncertain, and in the short term these acts do not appear to
have the potential of effectively administered direct conversion legislation
such as the Powerplant and Industrial Fuel Use Act.

1-14

TRANSPORTATION LAWS AND PROGRAMS

The three modes of coal transportation whose impacts are considered
here in terms of staLe and federal policy are waterborne transport, rail
transport, and truck transport. The most convenient distinction to be made
among these three modes is clearly that of water versus on-land movement.
Many impacts of coal transportation through the coastal zone by vessel are
unique to this mode, while rail and truck transport share some common impacts.
As a result of this distinction, policy to mitigate vessel impacts is often
unrelated to programs for the other two modes, and is generally federally
administered . On the other hand, many impacts of truck and rail movement of
coal are similar, such as noise and fugitive dust generation, and are often
dealt with by comprehensive federal and state programs, as well as by
mode-specific policies. This section identifies and evaluates the
applicability, effectiveness, and range the coverage federal and state policy
for dealing with the impacts of coal transportation.

COAL TRANSPORT BY WATER

Environmental impacts of the waterborne transport of coal are
primarily of two types: movement impacts and discharge impacts. Movement
impacts include land impacts such as shore erosion, impacts resulting from the
resuspension of particulates, and structural damage to onshore facilities.
The characteristics of ship operation which most directly determine these
impacts are vessel speed and nearness of the operation to the shoreline.

With respect to discharge impacts, bilge discharge would probably be
most important. Coal vessels do not store their cargo in ballast
compartments, so coal dust would not be expelled with ballast discharge. Coal
dust may however find its way into the bilges of ships and could, if expelled
have an uncertain effect on the marine environment.

Vessel Movement

In the Ports and Waterways Safety Act of 1978 Congress declares that
navigation, vessel safety and protection of the marine environment are matters
of national importance, and attempts to provide the necessary legislative
tools to prevent damage to structures in, on, or immediately adjacent to the
navigable waters of the United States or the resources within these waters (33
USC Subsection 1221 [a] and [c][21). The act also acknowledges that advanced
planning is critical in determining proper and adequate protective measures
for the nation's ports, waterways, and general marine environment, and
recognizes the necessity of continuing consultation among the federal and
state governments affected users, and the general public (33 USC Subsection
1221 [d]).

Due to the currenL assignment of the United States Coast Guard to the
U.S. Department of Transportation, the Secretary of Transportation is invested
with certain powers and responsibilities under the Ports and Waterways Safety
Act. In pursuit of the policy goals set forth in Subsection 1221 of the act,
the Secretary may, among other things:

1-15

� enact such measures necessary for protecting navigation
and the marine environment, including the establishment
of routing systems.

� establish vessel size, speed, draft limitations and
vessel operating conditions.

(33 USC Subsection 1223[al)

These broad powers enable the Secretary to establish rules and
regulations to protect the waters and coastline of the Great Lakes. To
mitigate coal vessel impacts, the Secretary can create rules concerning shore
proximity (routing systems), speed, and other vessel operating conditions
which influence movement impacts. Water quality impacts, or discharge related
impacts, may also be controlled by the Secretary under his board mandate to
"Protect the marine environment".

With respect to possible structural damage from vessel operation
within the coastal zone, the Act gives the Secretary of Transportation the
power to:

(1) prevent damage to, or the destruction of, any bridge or
other structure on or in the navigable waters of the
United States, or any land structure or shore immediately
adjacent to such waters; and

(2) protect the navigable waters and the resources therein
from harm resulting from vessel or structure damage,
destruction, or loss.

Action taken to prevent such damage may include but is not limited to
such me 'asures as establishing water or waterfront safety zones or other
measures for limited or controlled access or activity to protect any vessel,
structure, waters, or shore area. (33 USC Subsection 1225[al).

Regulations promulgated by the Secretary of Transportation to
implement the Ports and Waterways Safety Act are authorized under Section 1231
and may be found in Title 33 of the Code of Federal Regulations. (33 USC
Subsection 1231[al).

Title 33 of the CFR contains regulations relating in a general way to
navigation safety, and enforcement authority. By regulating such variables as
vessel speed, channel routes, and vessel size, impacts of coal transportation
such as shoreline erosion, resusupension of particulates, and on-shore
structural damage may be minimized. Speed limits between specific
geographical points and within individual harbors have been established
pursuant to the act for many Michigan ports and waterways. These include:
The St. Mary's River (Part 92.49); Keweenaw Waterway (Part 162.115); St. Clair
River (Part 162.135); Detroit River (Part 162.135); Rouge River and Short Cut
Canal (Part 162.140; and various harbors on Lake Michigan (Part 162.120).

In addition to these limitations, part 164.15 of Title 33 has general
safety rules concerning the responsibility of vessel owners or masters while
underway, including consideration for the nearness to fixed shore and marine

1-16

structures, the comparative proportions of the vessel and the channel, the
density of traffic, possible damage from the vessel's wake, and any local
speed I imits . Al I these variables affect shoreline erosion, particulate
resuspension and on-shore structural impacts.

Authority for enforcing the rules set forth in Title 33 can be found
in Part 160. This part states that the law enforcement responsibilities under
the Ports and Waterways Act are held by the United States Coast Guard District
Commander, "Captain of the Port", or an authorized representative of one of
these. Violation of a regulation issued under the act carries a civil penalty
of not more than $10,000 dollars.

Discharge Control

Impacts other than those from vessel movement would most likely be
discharge impacts and would be related to water quality protection laws and
regulations . The expulsion of coal dust containing liquids from vessels
operating in the Great Lakes and connecting channels would have an uncertain
impact on the environment, and clearly should be examined. Such discharge
would probably occur, if at all, as a result of fugitive dust finding its way
into a vessel's bilge, which often serves as a kind of "catch-all" for
uncontrolled vessel wastes and seepage.

The discharge of pollutants into the water of the United States if
addressed under provisions within the Federal Water Pollution Control Act (86
Stat. 816,868) and will be discussed later. The expulsion of such substances
by vessels however, does fall under the jurisdiction of the Secretary of
Transportation and the United States Coast Guard, and is addressed by Title 33
of the CFR. The discharge of liquid containing coal dust is not specifically
addressed in these regulations, as it may not be perceived a major problem.
However, to the extent that coal dust mixes with other bilge that is
regulated, it may be indirectly covered.

Parts 155.220, 155,340, 155.350, and 155.360 of the CFR require that
vessels may not operate without a system for retaining and controlling
disposal of "oily bilge slops." The discharge of such bilge is a violation
under the Water Pollution Control Act.

Evaluation

The actual enforceability and impact mitigation provided by the Ports
and Waterways Safety Act differs somewhat from the apparent coverage. The
interpretation of terminology for the actual enforcement of regulations,
geographical constraints on possible mitigating options, and possible policy
gaps, all contribife to a potentially less than effective vessel impact
mitigation program.

Though the Ports and Waterways Act does enable the United States
Coast Guard to issue "Captain of the Port orders" to prevent structural damage
to on-shore property, often resulting from vessel wakes, this power is
generally used to regulate extremely hazardous conditions. For example, a
burning ship or otherwise dangerous vessel could be ordered to anchor,
re-route, or behave in another manner if the Coast Guard determined that it
threatened persons or facilities on shore. Captain of the port orders,

1-17

however, are not generally issued to prevent wake damage to on-shore
facilities, or to regulate other by products of routine operation. Therefore,
damage resulting from day to day ship operation may not in actuality be
regulated in a preventative manner. At the same time, wake damage complaints
are handled by the Coast Guard after occurring, and action pursuant to these
may deter the production of destructive wakes. It should also be noted that
vessel wakes from coal transportation will not be different in kind from those
of other vessels of similar size.

Environmental problems related to the resuspension of particulates,
generally caused by vessel draw down and surge or propellor thrust, are
difficult to mitigate under the provisions of the Ports and Waterways Act.
Although shore proximity can technically be regulated by the Coast Guard, two
factors impede the effectiveness of this power. First , the distance of a ship
from shore while underway is not necessarily related to the depth of the water
it is in, and the latter is the determining factor in the resuspension of
bottom sediments. Coast Guard representatives contacted indicated that it was
next to impossible to regulate the closeness of a ship to the bottom of a
channel. Secondly, vessels generally use the safest, most direct channels
available, and unavoidably pass through shallow, frequently dredged areas
which are susceptible to particulate resuspension. This is especially true in
and around habors. Therefore the increase in vessel traffic which could be
caused by heavier coal related movement in the Michigan coastal zone may cause
a corresponding rise in undersirable particulate resuspensi.on problems.
Especially in areas which are frequently dredged (and dredging will be
required in many areas to accomodate larger vessels), problems such as water
turbidity may worsen.

Finally, regulations under Title 33 concerning bilge discharges may
not in all cases effectively control expulsion of coal containing liquids.
Though discharging oily bilge slops is, oil commonly floats on top of bilge
water, and the non-oily water below is not prohibited from being dischareed.
If coal dust mixes with this cleaner water, it may be expelled from vessels.
The effects of coal on the marine environment, both biologiclaly and
aesthetically, are not certain at this time; but if a significant quantity of
dust makes its way into bilge water, it may be expelled and cause harm.

1-18

NOTE S

Experts contacted included representatives of:

United States Coast Guard
9th District
Cleveland, Oh io

United States Coast Guard
Office of Marine Safety
Detroit, Michigan

U.S. Army Corps of Engineers
Detroit District
Detroit, Michigan

1-19

COAL TRANSPORT BY RAIL AND TRUCK

Environmental impacts from land based transportation fall into three
main categories; noise, air emissions, and land impacts. Noise mainly from
loading, unloading, and operating trains and trucks, could be substantial for
persons or communities exposed to unusually high levels. Air emissions '
specifically fugitive dust generation, may affect vegetation, water, air, and
various man made structures. Thirdly, land impacts, both on actual structures
and community function, may prove costly in terms of economics and community
safety as well as environmentally.

NOISE

Coal transshipment related noises in the coastal zone would come from
trains, trucks and loading *and unloading both types of vehicles. The
environmental effects of noise can range from relatively mild problems such as
occasional sleep disturbance at low levels, to severe medical and emotional
effects at extremely high levels. Members of both human and wildlife
communities may suffer such things as increased stress, central nervous system
damage (in extreme cases), and disruption of normal behavior patterns.
Greatly increased noise levels in the coastal zone, as a result of greater
coal movement, could therefore produce significant detremental effects in
certain areas. However, coal and other types of commodity transport are
already generating noise in many locations.

The Noise Control Act of 1972

The Noise Control Act of 1972 expresses the finding of congress that
inadequately controlled noise threatens public health and welfare and that
noise from transportation vehicles is a major source of this threat (42 USC
Subsection 4901[al). To promote an environment free from detrimental noise
levels, the act provides for coordination of federal research activities and
authorizes federal noise emission standards (42 USC Subsection 9401[b]).
Responsibility to coordinate all programs under this act lies with the
Administrator of the United States Environmetnal Protection Agency (42 USC
Subsection 4903[c][11) and with the United States Deprtment of Transportation
to regulate activities with which this study is concerned (42 USC Subsection
4916[b] and Subsection 4917[b]).

Rail Noise

Section 4916 [a][1] of the act mandates that the Administartor of the
Environmental Protection Agency, after consultation with the Secretary of
Transportation, shall publish regulations and standards for railroads engaged
in interstate commerce. The standards are to reflect the noise reduction
achievable by applying the best available technology, while taking into
account the cost of compliance. Consequently, the Secretary of
Transportation, after consultating the Administrator of the EPA, is to evolve
regulations to insure compliance with these standards through his powers of
enforcement and inspection under other Federal Acts (42 USCS Subsection
4916[b]).

1-20

The regulations referred to in Subsection 4916[a] [1] of the act can
be found in Title 40 Part 201 of the Code of Federal Regulations. These
promulgate standrads for both 1stationary and moving operation of locomotives
and the movement of rail cars.

All rail noise standards are in force when the dB(A) level, or
A-weighted sound level in decibels, is measured according to the technical
requirements of Subpart C of Part 201. It should be noted that these
regulations set standards for locomotives and railcars manufactured after
December 31, 1976, only, and are not retroactive. Older cars and locomotives
would seemingly be exempt. There are no regulations specific to unit-train
transport of coal. This activity would be covered under the provisions of law
generally.

Motor Carrier Noise

Section 4917 [a] of the act deals with creating standards for noise
from motor vehicles in much the same way as Subsection 4916[a] deals with
railroad noise . The regulations enacted pursuant to this section can be found
in Title 40 CFR Part 202, and took effect on October 15, 1975. They apply
only to motor vehicles engaged in interstate commerce, do not apply to
auxiliary equipment normally operated when the vehicle is stationary or moving
at less than five miles per hour, apply only to motor vehicles wihch have a
gross vehicle weight rating or gross combination weight rating of more than
10,000 pounds, and do not apply to warning devices such horns or sirens.
The specific regulations are found in Subpart B of Part 202

Section 4917[c][11 and [21 of the Federal Noise Control Act of 1972
specify that no state or political subdivision of a state may adopt of enforce
standards for operating motor carriers engaged in interstate commerce unless
they are identical to the standards proposed by the Federal regulations ad the
United States Secretary of Transportation has been consulted. The state of
Michigan has enacted regulations, under Act 300 of the Public Acts of 1949, as
amended by Act 73 and 492, Public Acts of 1978, which are identical to the
Federal standards for motor carriers and has thereby broadened noise control
coverage within Michigan to include state highways and streets, regardless of
the presence of an interstate activity. The Michigan act also broadens the
applicability of the standards to include all motor carriers with a gross
vehicle weight rating or gross combination weight rating of more than 8,500
pounds as opposed to the federally determined 10,000 pound level. (Ac t 300,
PA 1949, as amended by Act 73 and Act 492, PA 1978, Sec . 707c -
[11[a][i][ii][iii]).

Rules establishing test procedures for enforcement of the above
sections have been promulgated by the Michigan Department of State Highways
and Transportation, (Sec. 707e [11) and are still being reviewed. There are
no rules specific to coal transportation by motor carrier.

Evaluation

The preemption of noise standard setting authority by the federal
government has effectively limited state participation in controlling
transportaLion noise. Though the state has enacted truck noise standards
identical to those of the federal government, thereby regulating intrastate

1-21

transport, no action has been taken by the state with regard to rail noise.
The Environmental Protection Agency therefore maintains virtually all
authority over transportation noise, and new regulations in this area would be
expected to come from this source.

Policy gaps, or areas which could possibly benefit from further
regulations, seem apparent when comparing our current no'ise abatement
regulation with the various types and levels of environmental noise generated
during coal transportation. Foremost among these are inadequacies in the
current decibel emission limits for rail and motor carriers and lack of
regulation governing noise from loading and unloading vehicles.
Experts 3 agree that current decibel limits on rail and truck
equipment are not at an optimal level, although the technology to control
these emissions is now becoming available, and new vehicles are quieter. The
fact remains that the federal noise control program is relatively new, and
much equipment which was in use at its inception is still being used today.
For example, if we accept an estimate of twelve to fifteen years as the useful
life of a truck, we can clearly see that many trucks made to comply with 1975
standards are still in use, and lowering the acceptable level at this time
would adver@sely affect some truck operators.

In the past, truck emission standards have regulated the allowable
emission levels of all operating equipment, and changes in these standards may
still be several years aware because of the problem with older equipment.
Rail noise, on the other hand, has been regulated by limiting the allowable
noise of new equipment. This strategy does not discriminate against existing
equipment and tightens emissions limits as control technology develops. The
biggest problem with this strategy is its non-retroactive nature.

Another problem has been the lack of regulation of noise producing
activities such as loading coal into transport vehicles. The EPA has not in
the past been authorized to establish noise standards for processess, only
products. Work is being done, however, on Railroad Yard Property Line
Standards which could regulate rail yard noise as a whole, and could thereby
include coal loading and unloading. Questions still remain concerning the
definition of a "rail yard", what activities would be excluded from the
standards, and how the location of a given yard should affect the
applicability of the standards. Land use around rail yards would influence
whether of not the new standards would apply to a given facility, with
recreational uses of surrounding areas possibly being considered. Also
undetermined at this time is the issue of truck related noise and the
applicability of these regulations to facilities which may not clearly qualify
as rail yards. Utility spur lines for example, would probably not be included.

1-22

NOTES
Locomotives' manufactured prior to December 31, 1979 shall not
emit sound levels in excess of 93dB(A) [73dB(A) when at idle]
while stationary; and 96dB(A) when moving at any time, under any
conditions.

Locomotives manufactured after December 31, 1979 shall not emit
sound levels in excess of 87dB(A)[7OdB(A) when at idell while
stationary; and 90dB(A) when moving at any time under any
conditions.

� Effective December 31, 1976, no rail car or combination of rail
cars shall, while in motion, produce sound levels in excess of ff
dB(A) at speeds up to 72 km/hr. (45 mph) or 93dB(A) at speeds
greater than 72 km/hr. (45mph) (40 CFR 201)

2. 0 No motor carrier subject to these regulations shall operate any
motor vehicle of a type to whic@ this regulation is applicable
which at any time or under any condition of highway trade, load,
acceleration or deceleration generates a sound level in excess of
86 dB(A) measured on an open site with fast meter response at 50
feet from the centerline of lane of travel on highways with speed
limits of 35 MPH or less; or 90 dB(A) measured on an open site
with fast meter response at 50 feet from the centerline of lane
of travel on highways with speed limits of more than 35 MPH.

� No motor carrier subject to these regulations shall operate any
motor vehicle of a type to which this regulation is applicable
which generates a sould level in excess of 88 dB(A) measured on
an open site with fast meter response at 50 feet from the
longitudinal centerline of the vehicle, wh6n its engine is
accelerated from idle with wide open throttle to governed speed
with the vehicle stationary, transmission in neutral, and clutch
engaged.

� No motor carrier subject to these regulations shall operate any
motor vehicle of a type to which this regulation is applicable
unless the exhaust system of such vehicle is (a) free from
defects which affect sound reduction; (b) equipped with a muffler
or other noise dissipative device; and (c) not equipped with any
cut-out, bypass, or similar device.

� No motor carrier subject to these regulations shall at any time
operate any motor vehicle of a type to which this regulation is
applicable on a tire or tires having tread pattern which as
originally manufactured, or as newly retreaded, is composed
primarily or cavities in the tread (excluding si.pes and local
chunking) which are not vented by groves to the tire shoulder or
circumferential ly to each other around the tire. This Subsection
202.23 shall not apply to any motor vehicle which is demonstrated
by the motor carrier which operates it to be in compliance with
the noise emission standard specified for operations on highways
with speed limits of more than 35 MPH ...

1-23

Experts contacted included representatives of:

Office of Noise Abatement
Environmental Protection Agency
Washington, D.C.

Office of Testing and Research
Michigan Department of Transportation
Lansing, Michigan

Railroad and Port Facility Division
Michigan Department of Transportation
Lansing, Michigan

1-24

FUGITIVE DUST

Fugitive dust is produced during the loading, unloading, and
transportation of coal and may affect the coastal zone environment. During
loading and unloading, dust may be generated by collisions between pieces of
coal and/or the impacting of coal on dock surfaces or ship structures
following a free fall from equipment such as conveyors. During
transportation, wind blowing over uncovered coal being carried in trucks or
rail cars may also generate dust. Effects on vegetation, water, air, and
man-made structures are all possible by-products, and may be more significant
in the coastal zone because of nearness of dust sources to the waters, wind
pattern and velocity differences, and higher ground water levels.
Specifically, fugitive dust can cause problems with transpiration through
plant stomata, aesthetic effects, and other chemical and biological effects.

The Clean Air Act Amendments of 1977

Federal policy on air quality is implemented under the Clean Air Act
Amendments of 1977. In this act, Congress directed the United States
Environmental Protection Agency to establish primary and secondary National
Ambient Air Quality Standards [NAAQSI to protect the public health and
welfare, and directed the states to develop and adopt State Implementation
Plans [SIP's] to attain and maintain these standards. Part D of Title 1 of
the act outlines the necessary provisions of a satisfactory SIP for a
non-attainment area.

In August, 1977, the Acting Assistant Administrator for Air and
Waste Management of the Environmental Protection Agency issued a memorandum to
Regional Administrators concerning Guidance on SIP Development and New Source
Review in Areas Impacted by Fugitive Dust. The memo recognizes fugitive dust
as a significant contributor to the particulate matter problem within
urbanized areas throughout the nation and distinguishes between its impact on
rural versus urban areas.

... urban areas should receive the highest priority for
the development of a comprehensive and reasonable program
to control fugitive dust. Rural area control programs at
this time should center on the control of large existing
man-made fugitive dust sources (i.e., tailing piles,
mining operations, etc.) which in themselves are pre Isently
causing violations of the NAAQS or are sources of a known
toxic or hazardous material (e.g. asbestos).

The memorandum concluded by stating that fugitive dust control
measures, reflecting the application of reasonable available controls, should
be included in the SIP revisions which were then underway. It was recognized
that fugitive dust control programs would be new to many state and local
agencies, so time would be required to create effective programs in urban
areas.

The State of Michigan Air Quality Implementation Plan Revisions of
1979 contained provisions under the heading of Commitment for Fugitive Dust
Regulations, in which the state committed itself to developtng fugitive dust
regulations for at least the primary nonattainment area in Wayne County and

1-25

possibly a wider area. Rules have since been made for the entire state adding
fugitive dust control to the state implementation plan, and are currently
being reviewed. The Department of Natural Resources has committed itself to
January 1, 1981, for adoption of these rules into the Michigan SIP. In
addition to the statewide rules , Wayne County is evolving its own
requirements.

Included in the rules currently under review are sections which would
relate directly to fugitive dust created in the transportation of coal (see
Appendix). These may be cited as Proposed Rules R.336.1370-R.1372 of the
Michigan Administrative Code. Most important are R. 336.1371, Fugitive Dust
Control Programs, which describes the requirement for fugitive dust control
programs for applicable facility operators including coal transporters; and R.
336.1372, Fugitive Dust Control Program; Required Activities; Typical Methods,
which outlines necessary program content and typical control methods.

Evaluation

If adopted, and it appears fairly certain that they will be, the
rules currently under review should be effective in mitigating many impacts of
the fugitive dust problem as it relates to coal. Specific rules include
provisions to deal with coal dust generation problems in storage piles (Rule
372[a][i]), loading and unloading (Rule 372[a][ii]), truck transport (Rule
372[b]), and outdoor conveying (Rule 372[c]).

One policy gap, a potentially important one, exists for dust
generated in the transport of coal by rail. Rail transportation is partially
covered by the proposed regulations dealing with the general loading and
unloading of bulk materials (Rule 372[a][i] and [ii]), but does not receive
the attention concerning wind blown dust during transport that truck
transportation does. While regulations have been proposed requiring such
things as completely covering open bodied trucks, the use of completely closed
trucks, and tarping empty trucks containing residue, provisions for similar
results have not been suggested for rail cars.
Experts 1 in the Michigan Department of Natural Resources have
indicated that rail regulations in the proposed rules were not as extensive as
those for trucks for several reasons, foremost of which seemed to be the
perception that train movement was not as important a source of fugitive dust
as truck transport. Numerous studies have concluded, however, that dust
generated by rail transport of coal is significant. A publication of the U.S.
Environmental Protection Agency entitled Environmental Assessment of Coal
Transportation indicates that:

Loss of particulates in transit varies with type of coal
shipped, condition of the cars, moisture and fines contents
of the coal, speed of the train, and wind speed. The
estimates of wind losses range from negligible to 1.0 percent
of the coal shipped. Some reports place the losses in
certain situations at 5 tons per car during a trip over 480
km (300 miles) . The losses do vary widely, probably
averagin@ between 0.05 and 1.0 percent of the total coal
shipped.

1-26

Though coal may not travel great distances by train within Michigan,
it appears clear that substantial fugitive dust can be generated by rail
movement. The Department of Natural Resources should therefore re-examine the
possibility of including explicit coal dust mitigating measures in its State
Implementation Plan Revisions to more thoroughly deal with the fug'itive dust
problem.

1-27

NOTES

1. Experts contacted included representatives of

Michigan Department of Natural Resources
Air Quality Division
Lansing, Michigan

2. United States Environmental Protection Agency, Environmental Assessment of
Coal Transportation, National Technical Information Service, Spring'Fli-eTl,
VA. May 1978, p. 77.

1-28

OTHER RAIL AND TRUCK IMPACTS

Community Interference

Another impact of coal transportation is coal train interference with
the activities of communities through which they pass. Special attention may'
be warranted for unit trains, which are generally longer and slower moving
than other types of rail transport and may cause more disruption than
traditional coal trains. A study for the Minnesota Department of
Transportation and the North Dakota State Highway Department is currently
underway concerning Alternative Solutions to Railroad Impacts on Communities
(Ernst and Whinney, 1979), but as of this writing is not complete. This study
may have important implications for coal train movement in Michigan since the
impacts on Michigan communities should not differ greatly from those in other
states.

The most important disruption may be the amount of time for which a
train, effectively "divides" a community, perhaps hampering emergency services
or endangering and inconveniencing motorists and pedestrians. The State of
Michigan Compiled Laws do limit the obstruction of vehicular traffic by a
railroad train to five minutes (1970 Michigan Compiled Laws Annotated 466.23).
It is also unlawful for successive train movements to obstruct any vehicular
traffic on any public streets or highways until all previously delayed traffic
has been cleared, or a period of five minutes has elapsed between train
movements, and penalties are provided for violation (Secs. 466.24 and 466.25).

Evaluation

Although these laws appear to cover the problem of vehicle disruption
quite thoroughly, the average time for which a unit train blocks a crossing
ranges between 1.5 and 3.4 minutes (Ernst & Whinney, 1979), and crossings of
such a duration are not regulated under the above laws. To efficiently assess
and regulate the impact of unit train movement through a community, one must
consider factors such as total traffic delay times, which often are more
substantial than the actual times of crossing, and do not seem to be currently
regulated in Michigan.

Current policy, therefore, seems inadequate to deal with coal train
impacts. The relatively recent and more significant development of unit train
transport may explain why past policy has not addressed such questions as
train interference with communities in a comprehensive manner. However the
current community impact of these trains, as well as an expected increase in
rail movement of coal, requires a thorough investigation of mitigation
strategies.

The study mentioned above which is being conducted for the Minnesota
Department of Transportation and the North Dakota State Highway Department,
attempts to address the problems of community interference in a comprehensive
manner. Potential low cost solutions being examined include the modification
of current railroad operating practices, railroad facilities, community
transportation facilities, railroad/community communication, community
development patterns, community services, and behavior modification (Ernst and
Whinney, 1979). Some or all of these potential solutions may be applicable to

1-29

communities in the Michigan coastal zone, and should be examined if such
problems are identified in specific communities.

Road Damage - Truck Weight Restrictions

Michigan Vehicle Code, Ac@_300, Public Acts of 1949 as amended

The two greatest factors involved in road damage from trucks would be
the weight of the trucks and the frequency with which they travel any given
roads. Michigan does have Maximum Truck Loadings and Dimensions (Michigan
Department of Transportation, Numbered T-1 1/79), regulations pertaining to
the operation of trucks and trailers according to Act 300, P.A. 1949 as
amended. Truck dimensions in Michigan are not restricted strictly by weight,
but rather by number of axles and vehicle configuration. Special permits are
issued by the Department of Transportation for the occasional movement of
oversize or overweight vehicles or loads which cannot be dismantled, reduced,
or otherwise rearranged to come within the legal limits (See Tables in
Appendices) .

The upper limit under Michigan law for any one axle is 18,000 lbs.,
with a maximum allowable axle limit of eleven. Vehicle configurations and
axle spacings are also regulated. Michigan's truck weight restrictions are
considered quite lenient relative to regulations in other states. Highways
in Michigan are, however, designed to withstand the 18,000 lb/axle load over a
twenty year life span.

Evaluation

Though other states have stricter overall weight limits, they often
allow heavier per axle weights. Interstate traffic therefore, may exert a
greater negative impact on Michigan highways, although frequency by heavy
truck use is also a factor, and because of its location Michigan may not have
a lot of interstate traffic.
Experts1 in the Michigan Department of Transportation feel that the
state's truck loading regulations are generally sufficient to protect
Michigan's highways from excessive damage. Though some trucks may overload,
this practice is illegal, and highway weigh stations are operated in an
attempt to enforce state limits. New weighing methods are being developed for
more accurate weighing of individual axles.

In short, it appears that the state's policy on truck weight
restrictions will be adequate to deal with increased coal movement in
Michigan. If there is a potential policy problem, it may be with respect to
interstate coal traffic in the state.

1-30

NOTES

Experts contacted included representatives of

Michigan Department of Transportation
Lansing, Michigan

- Design Division
- Planning and Programming Division
- Maintenance Division

1-31

TABLE 1-2

MAXIMUM OVERALL DIMENSIONS

96inches
Height ........................................................ 13 feet, 6 inches
Length of semi-trailer or trailer No Restriction
Length of any other vehicle with or without load (excluding impact absorbing bumpers) . . . . 40 feet
Units permitted in train - - - - - - - - - - Truck-tractor, semitrailer and trailer or truck and semitrailer or trailer.
Length of a combination of truck-tractor and trailer or semitrailer with or without load 55 feet
Length of a combination of truck-tractor and semitrailer with or without load, with semitrailer
not exceeding 45 feet . . . . . . . . . . . . . . . . . . . . .60 feet
-tractor, sem rai ;t a
Length of a combination of truck i; 'ler *a'n@ *tr*ail;; o ruc nd semitrailer or
trailer with or without load . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59 feet
Projection beyond front of vehicles 3feet
Overhang beyond rear of vehicles Any amount is permissible if the legal overall length is not exceeded.
But if this overhang is 4 feet or more, there shall be displayed on the extreme rear of such load a 12
inch red square flag in the daytime and a red light or lantern at night.
Axle Limitation A combination of vehicles shall not have in excess of 11 axles .

1-32

TABLE 1-3

TA3LE OF MAXIMUM ALLOWABLE GROSS AXLE LOADINGS
Normal Loading Special Designated Highways t
When Limitations SPECIAL NOTEt Seasonal Load Limitations
Spacings Between A truck-tractor and semitrailer transport- (Speed Limit 35 MPH)
Are Not in Force ing flammable liquid in bulk which has a
Axles (Speed Limit flush point at or below 70 degrees fahren-
heit. may be operated (at the gross and Rigid Flexible
55 MPH) axle weights provided for In this column)
on a highways that are designated
.!I state
as All Season Routes".
9 feet or over 18,000 tbs. 20,000 tbs. 13,500 tbs. 11,700 tbs.
More than 31/2 feet but less than 9 feet 13,000 tbs. 13,000 tbs. (34,000 tbs. for tandem axle) 9.750 tbs. 8,450 tbs.
When part of a tandem axle assembly 16,000 tbs. 34.000 tbs. per tandem 12,000 tbs. ***10,400 tbs.
When less than 31/2 feet the combined
weight shall not exceed 18,000 tbs. 20,000 tbs. 13,500 1 bs. 11,700 tbs.
Maximum load on any wheel shall not ex- I
ceed:(pounds per inch of tire width) 700 tbs. 700 lbs, 525 tbs. 11 450 tbs.

tGross weight may not exceed the following: An overall gross -eight on a group of 2 or more consecutive axles equaling!
(LN
W = 500 (--+ 12N + 36)
N-1
where W = overall gross weight on a group of 2 or more consecutive axles to the nearest 500 pounds, L @ distance in feet
between the extreme of a group of 2 or more consecutive axles. and N = number of axles in the group under consideration;
except that 2 consecutive sets of tandem axles may carrv a gross load of 34.000 pounds each if the first and lost axles
of the consecutive sets of tandem axles are not less than 36 feet apart, and the gross vehicle -eight does not exceed
80,000 pounds including all enforcement tolerances.

A vehicle or combination of vehicles when utilizing an additional 5 miles from a "Special Designated Highwav" for
access to or from points of origin or destination, must reduce to the following axle weights when the route being traveled
is under seasonal iond limitations: Rigid route - 15,000 lbq. on a single axle. 25,500 lbs. per tandem. Flexible route
13,000 tbs. on a single axle, 22.100 lbs. per tandem.

On any legal combination of vehicles, only one (1) tandem axle assembly shall be permitted at the gross weight of 16,000
lbs. per axle and no other tandem axle assembly in such combination at vehicles shall exceed a gross -eight of 13,000
tbs. per axle. When the gross weight of a combination of vehicles with load, does not exceed 73,280 lbs., two (2) tandem
axle as s blies shall be permitted at a gross weight of 16.000 tbs. per axle.
On any lZal combination of vehicles, only one (1) tandem axle as.5embly shall be permitted at the gross weight of 12,000
lbs. per axle and no other tandem axle assembly in such combination of vehicles shelf exceed a gross weight of 9,750 lbs.
,I)- n .1

per axle. When the gross weight of a combination of vehicles with load does not exceed 73,280 lbs., two (2) tandem
axle assemblies shall be permitted at a gross -eight of 12,000 lbs. per axle.

On any legal combination of vehicles, only one (1) tandem axle assembly shall be permitted at the gross weight of 10,400
tbs. per axle and no other tandem axle assembly in such combination of vehicles shall exceed a gross weight of 8,450 lbs.
per axle. When the gross weight of a combination of vehicles with load does not exceed 73,280 lbs., two (2) tandem
axle assemblies shall be permitted at a gross weight of 10,400 lbs. per axle.

FIGURE I-1

MAXIMUM GROSS AXLE LOADS

The following examples are shown as a guide for figuring the maximum allowable gross axle loads on all
State Trunk Lines during all periods of the year.
MINIMUM TIRE REQUIREMENTS: The maximum load on any wheel shall not exceed 700 pounds per inch
of tire width.
Illustrations of
axle spacings:

01
6502 2 3 4 5 6 7 8
Less Less I e:,, [ Less 9' or
than V-6'
3 L n
P-6 91 or th han
over 9 9,01 9, over
min 9. .7 9. 9,

Co W 00
CD CD (Z (0 CD C
CD CD 0
C

Public Act 11#36, 1965

2 3 "When the maximum gross weight of a combination of
vehicles with load does not exceed 73,280 pounds, 2
tandem axle assemblies shall be permitted at a gross
Imin-1 over I min-1 permissible weight of 16,000 pounds for any such in-
a% Cn C., dividual axle."
@2 5@
6@2 "0

9' or I '-o.

1-34

FIGURE 1-2

7 AXLE
3 UNIT
MA
AXLE LOADS
91 1 18 18 18 16 16
9' 9' -1- 9- 4@
55' MAX.

NOTE:
.3N 6 AXLE
NUMBER IN CIRCLE SINGLE UNIT
INDICATES 1000 LBS MAX.= 42 TON
PER AXLE.
AXLE SPACING IS FOR 16 16" 13 13 13 13
TYPICAL VEHICLES, @41

. . ........
11 AXLE
2 UNIT
AX.= 77 TONS

1 16 13 13 13
7'4- 10.51 71-@

11 AXLE
UNIT
MAX.=
Is Is... 16 13 1 1 13 13 77 TONS
9.5'--@ 4' 91

WX@

............. . 11 AXLE
..........
.........
3 UNIT
- - - - - - - - - -
MAX.
15 16 18 18 82 TON
4' 9'--@
.65' MAX.ON DESIGNATED HIGHWAYS

EXHIBIT B
MAXBIL-NI GROSS VEI-11CLE WEIGHTS IN MICHIGAN IN 1970

1-35

ENVIRONMENTAL LAWS AND PROGRAMS

AIR QUALITY PROGRAMS RELATED TO DEMAND FOR COAL

Introduction

2 The Federal Clean Air Act, initially adopted in 1970 and amended in
1977 , is a complex piece of legislation. The 1977 Amendments, in particular
illustrates Congressional awareness of the often conflicting demands oi
environmental and energy policies. To the extent that coal-burning facilities
typically have a greater potential for emitting air pollutants than do
facilities using other energy sources, the 1977 Amendments may require greater
expenditures for pollution control equipment or be subject to stricter siting
procedures. On the other hand, provisions of the Act encourage development of
coal-fired sources as a means of reducing dependence on other fossil-fuels.

The discussion of the Clean Air Act which has been incorporated into
this report represents a bare outline of essential provisions of the Act as
related to combustion of coal and the anticipated effects of air quality
standards in affecting demand for coal. A separate section will focus
specific discussion on implementation of regulatory air quality provisions
concerning transportation, handling, and stockpiling of coal.

New Source Performance Standards

One of the central features of the Clean Air Act, provides that the
EPA Administration must establish standards of performance for new and
modified stationary source of air emissions. For the purpose of formulating
those regulations, EPA has identified at least 28 categories of sources which
must apply3 the best demonstrated technological system of continuous emission
reduction. In additiot4, fossil-fuel-fired sources are subject to percentage
reductiion in emissions.

Theoretically, complying with federal emissions standards should not
be a problem. The EPA Administrator is supposed to set emission standards on
the basis of demonstrated "best available control technology" (BACT) .
Establishment of standards for control of particulates and NO emissions has
been relatively noncontroversial. However, the SO 2 emission 2 standards have
proven enormously controversial as evidenced by continuing disagreement
amongst environmentalists and utility industry spokesmen over whether current
standards should be tightened or made more lenient.

Current SO regulations require that new coal-burning utility
facilities capable oi firing more than 73 MW (250 million BTU/hour) of fossil
fuel (a) shall emit sufur dioxide in concentrations not exceeding 1.20
lb/million Btu, and, in addition, shall achieve a 90% reduction, in potential
concentration; except (b) where sulfur dioxide emissions are reduced to
concentrations not exceeding 0.69, lb/million Btu, when only a 70% reduction in
potential emissions is required. Incidentally, the regulations provide that
the industry may take credit for any cleaning of the fuel, or reduct@)n in
pollutant characteristics of the fuel after mining and before combustion.

1-36

In establishing different requirements for emission reduction, one of
the principal issues pertinent to coal transportation concerns whether a
utility burning low-sulfur coal s @ould be required to achieve the same
percegtage reduction in potential SO emissions as those burning higher sulfur
coal. According to legislative history accompanying the 1977 Amendments, the
emission reduction requirement waste be applied uniformly to all types of coal
irrespective of sulfur content, unless the Administrator determined that
varying requirements would not undermine the intent of the Act to maximize use
of locally available coal resources:

In establishing a national percent reduction for new fossil
fuel-fired sources, the (Senate-House conferees agreed that
the Administrator may, in his discretion, set a range of
pollutant reduction that reflects varying fuel
characteristics. Any departure from the uniform national
percentage reduction requirement, however, must be
accompanied by a finding that such a departure does not
undermine the basic purposes of the House provision and
other provisions of the 1bt, such as maximizing the use of
locally available fuels.

After conducting an extensive investigation, the Administrator issued
a determination that a variable sulfur emissions strategy was justified and
would not undermine the Act's proposes of encouraging use of locally derived
coal. According to the investigation, the non-uniform options considered
resulted in only small shifts in regional production of coal, principally
involving a potential decline in Great Plains production and a potential
increase in western production. Mining production in other areas including
the Great Lakes states was expected to remain relatively unaffected by the
options.

Table 1-4 presents results of EPAs analysis of control options and
provides projections of their effect on 1995 coal production. Of particular
interest, the EPA analysis indicates that western coal transport under all
options will be at least three times higher than 1975 levels.

The results of the analysis also suggest that "variable control"
levels with a minimum potential emission reduction set at 90 and 70 percent
(represents the adopted option) should result in about 27 million tons more
western coal being transported east than uniform standards (the "full control"
option represents a uniform standard of 1.2 lb/million Btu emission limit with
a 90 percent reduction in potential SO 2 emissions). However, it should be

These standards do not apply to existing utility facilities that were
designed to use gas or oil fuels and that are modified to burn coal. These
standards also do not apply to industrial boilers. EPA is currently
developing standards for industrial boilers which it plans to propose in
late 1980 or 1981.

1-37

specifically noted that only a small fraction of the anticipated 27 million
tons of additional western coal transported east would be transported through
Great Lakes connecting channels and an even smaller portion would ultimately
be utilized in Michigan.

As noted previously, these new source performance regulations pertain
only to new and modified electric utility steam generating uriits capable of
firing more that 73 MW (250 million Btu/hour) heat input of fossil fuel.
Except for large industrial cogeneration facilities (sales of at least 25 MW
of electricity and at least one-third of potential output), industrial boilers
are not presently covered by new source performance regulations. 8 However
these regulations reportedly are in the process of being developed . Given
the precedent established in developing new source performance standards for
electrical generating facilities, it can be anticipated that , when
promulgated, SO 2 regulations will require less extensive (though still
substantial) emissions control possibly in the form of partial scrubbing
and/or other continuous control technological systems. In addition, it is
reasonable to anticipate that the effects of new source industrial performance
standards on regional patterns of coal mining and transportation will be
relatively insubstantial compared to the regional demand effects of standards
for electrical generating facilities.

1-38

TABLE 1-4
IMPACTS ON FUELS IN 1995a

Level of control b

1975 Current Full Partial Variable

actual standards Control Control Control

33% 70%

Minimum Minimum

Wet Dry Wet Dry Wet Dry Wet Dry

U.S. Coal Production (mill.

tons):

Appalachia 396 439 524 463 465 475 486 470 484

Midwest 151 404 391 487 488 456 452 465 450

Northern Great Plains 54 655 630 633 628 622 576 632 602

West 48 230 222 182 180 212 228 203 217

Total 647 1,778 1,767 1,765 1,761 1,765 1,742 1,770 1,752
Western Coal Shipped East
(million tons) 21 122 99 59 55 68 59 71 70

Oil Consumption by Power
Plants (Million bbl/day):

Power Plants 1.2 1.2 1.6 1.6 1.4 1.4 1.4 1.4

Coal Transportation* 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

Total 3.1 1.4 1.4 1.8 1.8 1.6 1.6 1.6 1.6

*Results of EPA analyses completed in May 1979 based on oil prices of
$12.90, $16.40 and $21,00/bbl in the years 1985, 1990, and 1995, respectively.
*With 520ng/J maximum emission limit.
*Based on wet SO 2 scrubbing costs.

1-39

National Ambient Air Quality Standards

A major feature of the 1970 Clean Air Act Amendment was the
requirement that EPA formulate National Ambient Air Quality Standards (NAAQS)
defining two types of target levels for ambient concentrations of pollutants:
primary standards intended to protect public health; and secondary standards
for maintaining public welfare consistent with factors other than human
health, including effects of pollutants on vegetation, materials, visibility
and weather.

Primary and secondary NAAQS have been promulgated by EPA for seven
pollutants known to have potentially adverse effects on public health and
welfare: sulfur oxides (Sox), particulate matter, nitrogen dioxide (NO ),
hydrocarbons, ozone, carbon monoxide (CO), and lead. Current standards ior
Sox, particulate matter, and NO 2) the primary byproducts of coal combustion,
are included in Table 1-5.

After establishment of NAAQS, the specifics for achieving ambient air
quality compliance are to be prescribed by state implementation plans (SIPs).
A legally sufficient plan, according to Section 110 (a)(2) must be adopted by
the state after reasonable public notice and hearing, and must address:

(A) attainment of primary standards (as expeditiously as
possible but within three years from date of plan approval)
and attainment of secondary air quality standards (within a
11reasonable time"); (B) emission limitations, schedules and
timetables and other measures such transportation control
and quality maintenance plans as necessary for achieving air
quality standards; (C) monitoring of ambient air quality;
(D) administration and enforcement including provisions for
pre-construction review of new sources, (E) inspection and
testing of motor vehicles to the extent necessary; and (F)
authority for plan revision.

The following information on areas of nonattainment and in plans 9 to
rectify identified problems is summarized from the State Implementation Plan

A. Particulate Matter

1. Geographic Areas of Nonattainment

As indicated in Figure A, many areas exhibit no significant change in
ambient air quality conditions for particulates. However, coastal counties
trends data does indicate that suspended particulate air quality is improving
(from west to east) in Ontonagon, Marquette, Muskegon, Alpena, losco, and
Monroe.* Only two counties (Menominee and Mason, both adjacent to Lake
Michigan) have experienced worsening air conditions insofar as suspended
particulates. Expressing these results in terms of human exposure, in 1967 an
estimated five million Michigan residents were exposed to concentrations of
total suspended particulates above the health related standard. By 1977, the
exposed population had dropped to approximately 600,000, most of when are
residents of heavily industrialized Wayne County. Other nonattainment areas

Eaton is the only inland county where suspended particulate concentrations
are reported to be significantly improved.
1-40

TABLE 1-5

NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PARTICULATE MATTER,
SULFUR DIOXIDE, AND NITROGEN DIOXIDE

Averaging Primary Secondary
Pollutant time standard standard

Particulate matter Annual
(geometric
mean) 75 ug/m 3 60 ug/m 3
24-hour 260 ug/m 3 150 ug/m 3

3-hour

Sulfur dioxide Annual

(arithmetic
mean) 80 ug/m 3
24-hour 365 ug/m 3
3-hour 1,300 ug/m 3

Nitrogen dioxide Annual
(arithmetic
mean) 100 ug/m 3 100 ug/m 3

24-hour

3-hour

*Based on dry SO 2 scrubbing where applicable.

Source: Federal Register / Vol. 44, No. 113 / Monday, June 11, 1979, pages

33605-9

1-40

include Albion, Saginaw and Flint . While this represents substantial
progress, it also indicates that additional action is necessary, for achieving
compliance with ambient air quality standards for particulates as follows.

As indicated, four areas - Detroit, Saginaw, Flint and Albion, ten
counties in all - fail to meet the primary standard for suspended
particulates . Sixteen additional counties do not currently meet the more
stringent secondary standard for suspended particulates.**

2. Programs for Improving Air Quality

For three primary particulate matter nonattainment areas (Saginaw,
Flint, and Albion), the Michigan Air Quality Division believes that it has a
sufficient understanding of the causes of nonattainment to provide assurances
that the management approach being proposed will be sufficient to achieve
ambient air quality compliance.

In Detroit, the sufficiency of the available information necessary
for assuring achievement of applicable standards is even more suspect in that
numerous establishment and sources are likely causing the nonattainment
problem over an extensive region.

In contrast to the other primary nonattainment areas, it has been
recognized that sources of the nonattainment are far more numerous, making it
more difficult to monitor and manage area sources. Nevertheless, historical
ambient monitoring effects (discussed previously) has suggested continued air
quality i-mprovements including the Detroit area. Moreover, with respect to
emission reductions since 1975, the state lists 23 sources of particulates in
the Detroit area which have already undergone (or will undergo) emission
reductions of greater that 100 tons per year.

Research efforts and studies necessary for linking particulate source
problems to ambient conditions in at least four areas identified by the
state as in violation of secondary air quality standards has been
undertaken.

1-41

The state is also committed to providing further progress in the
Detroit nonattainment area by:

1. continuing to enforce RACT (Reasonably Available
Control Technology) regulations for point sources,
2. enforcing new fugitive emission regulations when
enacted,
3. continuing to enforce fugitive emissions currently
covered under enforcement orders (e.g., coke
batteries),
4. enforcing an emission offset policy,
5. conducting additional study (primarily microscopy) to
determine the reason or reasons for nonattainment.

On such evidence the State Air Quality Division does maintain that
reasonable further progress can be anticipated in the Detroit arep. However,
largely because of problems in modeling particulates in the area , it is not
presently possible to comply with requirements of the Clean Air Act that call
for demonstration by the state that ambient air quality standards can be
attained.

In summary of the implementation plan for attainment of ambient air
quality standards for suspended particulate, historical evidence indicates
that progress is being made. Moreover, in the near future, efforts will be
made by the Air Quality Division to control all identifiable sources of
particulate matter within major areas of nonattainment, including fugitive
dust, through the development of abatement orders. In areas of secondary
standard violations, specific study programs have been suggested and are being
carried out.

Sulfur Dioxide

Currently nearly all areas of the state are meeting the sulfur
dioxide primary standards. Therefore, no change in the existing sulfur
dioxide emission limits or control programs are proposed under the State
Implementation Plan.

It should be noted that, to date, achievement of sulfur cleanup in
the state has been accomplished mainly by encouraging coal users to utilize
low sulfur coal, and in some cases, by permitting taller stacks for disperse
sulfur discharges.

A discussion of problems encountered in validating models of particulate
pollutants in the Detroit area and in completing detailed microscopy analysis
is outlined in pages 2-8 to 2-24 of the State Implementation Plan.

1-42

EPA and the state do intend over time to provide for the elimination
of what are called "supplemental control systems" in favor of "constant
emission control systems." The supplemental systems, responsible for
nonattainment status of two geographically limited areas - one in Monroe
County and one in Ingham County - are based on the idea of controlling
emissions only at certain times when meteorological conditions are presumed to
be inadequate for dispersion of emissions. During these times, the companies
utilizing only "supplemental control" switch from high to low sulfur fuel.
However, a's indicated, the state is committed to replacing such practices with
constant emissions control such as constant burning of low sulfur fuel or use
of flue gas desulfurization technologies.

New Source Review

The State Implementation Plan provides for a review program for new
sources which has been designed to assure that developments occurs in a manner
consistent with standards for ambient air quality. This review process will
involve consideration of the proposal in terms of categories of pollution
(e.g. sulfur dioxide, suspended particulates etc.) which the proposed source
can be expected to emit. For each pollutant category, it is anticipated that
the adopted State Implementation Plan will be utilized to indicate whether the
proposed emissions involves an area of attainment or non-attainment.

A. Project Review in Nonattainment Areas

In nonattainment areas a permit for a major air pollution source
cannot be issued unless the permit complies with Section 173(1)a of the Clean
Air Act. Section 173 requires that all major new sources install equipment
which is designed to meet the lowest achievable emission rate (LAER). The
applicant must also demonstrate that all sources owned by the applicant
located in the state are in compliance with the State Implementation Plan or
on an enforceable schedule to come into compliance. And finally, emission
offsets must be provided so that when the new source becomes operational,
existing sources will have decreased pollution a sufficient amount to produce
a net air quality benefit.

B. Project Review in Areas of Attainment with Air Quality Standards

With respect to attainment areas, growth will be provided consistent
with federal prevention of significant deterioration regulations. Under the
1977 Amendments, areas having air quality better than the national secondary
ambient standards must be zoned into one of three categories. Significant air
quality deterioration is prohibited in all zones, but "significant" is defined
differently in each category. In Class I areas, almost any decrease in air
quality will be regarded as significant. In Class II areas, a decrease in air
quality beyond r-hat associated with "moderate, well-planned growth" will be
assumed to be significant. In Class III areas, only deterioration beyond that
resulting from heavy industrial development using the "best available control
technology" will be considered significant and thus prohibited. Deterioration
beyond the national secondary ambient standards is prohibited in all zones
regardless of the increments otherwise permitted under provisions for
preventing significant deterioration.

1 1-43

Rules 203 (2), 203 (3), 205 and 231 through 237 promulgated by the
State Air Pollution Control Commission have effectively zoned areas of
attainment in Class II areas. Under the rules, new proposed sources require
compliance with minimum federal requirements for prevention of significant
deterioration. These rules generally require the application of best
available control technology and limit the cumulative air quality impact for
all new major sources.

1-44

EVALUATION

State Administration

1. Air quality monitoring and development and implementation of air quality
control sufficient to achieve ambient air quality standards are among the
responsibilities of the Air Pollution Control Commission, an appointed
statewide citizen committee, and the state Air Quality Division of the
Department of Natural Resources.

Air Quality Conditions

2. Results of air quality monitoring by the state are briefly summarized
within this report. More extensive information can be obtained from the
State Implementation Plan or directly from the Air Quality Division.

Relevance of New Source Performance Standards to Coal Transportation, General

3. Combustion is a step of the coal fuel cycle which is largely beyond the
scope of the present study, however a summary of new source performance
standards for coal burning facilities has been provided in that such
standards influence demand for coal. New source performance standards
have been promulgated for particulates, No 2 and SO 2 emitted from
electrical utility facilities. New source performance standards are also
currently being developed for industrial coal-fired boilers. New source
performance standards are uniformly applicable to all regions of the
country and should not create special regulatory hardships upon new
industries and utilities interested in siting in Michigan.

Relevance of SO New Source Performance Standards in Impactors Regional Demand
for Coal

4. The EPA Administrator has adopted a "variable control" SO standard, with
90 percent emission reduction required of high sulfur coa? and 70 percent
emission reduction required of low sulfur coal. This "variable control"
strategy is expected to result in somewhat greater use of western coal by
eastern states in the year 1995 then would have resulted under uniform 90
percent emission control requirements. The amount of additional
transported western coal, estimated at 27 million tons, represents about
23.7% greater volume of eastward transport of western coal. EPA studies
conducted prior to selection of the variable control strategy have
indicated to the Administrator that the adverse effects of this increase
in use of distant sources of coal is offset by future advantages of
variable source control levels including promotion of advance technology,
retirement of obsolete electrical generation facilities, and anticipated
cost savings.

Recognized Sources of Coal-Generated Particulate Source Pollution

5. Compliance with national ambient suspended particulate standards has
proven difficult for the state and, for that matter, for most other
regions of the country as well, largely because sources of particulate
contamination are more extensive and varied. In contrast to sulfur and
nitrogen dioxide pollution generally impacted by coal use only during the

1-45

combustion stage), particulate pollution occurs at every step of the coal
fuel cycle and every site in which coal is mined, processed, transported,
stored or burned.

State Areas of Noncompliance with Primary Particulate Standards

6. Primary Standard particulate nonattainment includes areas in the vicinity
of Detroit, Saginaw, Flint and Albion. The most serious problems in
attaining compliance exist in the Detroit/Wayne County metropolitan
region.

Established Trend in Cleanup of Particulates

7. Available information does suggest that significant improvement in ambient
concentrations of particulates has been achieved.

Control Programs for Continued Cleanup of Particulates

8. The state is continuing its efforts to achieve statewide compliance with
ambient standards for - suspended particulates. In particular, the Air
Quality Division intends to require control of existing sources of
particulate matter within areas of nonattainment, including fugitive dust
control for at least the Detroit primary nonattainment area. In those
regions of the state where it is not possible to demonstrate attainment
with the primary or secondary standards for particulate matter, emission
offsets for all new sources seeking to locate within the nonattainment
areas is required. The emission rule in part, requires the operator of a
proposed new source of particulates to provide for the control of an
existing source(s) of particulates within the nonattainment area so that
the overall effect is to achieve a net air quality improvement.

State Areas of Noncompliance with Primary SO Standards

9. Most of the state is presently in compliance with the SO 2'national ambient
air quality standards. Those regions of the state not currently in
compliance should attain the SO 2 primary ambient air quality standards
within the near future.

State New Source Air Pollution Review Procedures

10. The state has adopted procedures for review of new sources of air
pollutants.

Implications of Control Programs and Future Coal Use

11. Overall, the state appears to have made excellent progress in developing
necessary programs for attaining and maintaining compliance with air
quality standards. Progress achieved will help to assure accommodation of
projected increased in coal use consistent with standards for maintenance
of environmental quality.

1-46

AIR QUALITY PROGRAMS RELATED TO TRANSPORTATION OF COAL

EPA in 1977 ordered that urban area fugitive dust control measures
must be included in future revisions of the State Implementation Plan. (see
transportation section) . Included in rules currently being promulgated are
sections which are directed at control of fugitive dust resulting from coal
transportation, handling, and storage.

If adopted, specific rules will deal with many of the identifiable
points of generated coal dust including: storage piles, loading and
unloading, truck transport and outdoor conveyance. Conspicuously missing are
regulations capable of addressing wind blown dust resulting from train
transport. For a more detailed discussion of proposed fugitive dust
regulations, please see the transportation policy section.

EVALUATION

1. Recognized Sources of Coal-Generated Particulate Source Pollution.
Information contained in this report's discussion entitled "Air
Quality Programs and Their Impact on Demand for Coal Use" identifies
areas of nonattainment for suspended particulates. In contrast to
sulfur and nitrogen dioxide coal-derived pollutant loads which are
generated only during the combustion stage, suspended particulates
may occur at every step of the fuel cycle and at every site in which
coal is mined, processed, transported, stored and burned.

2. Possible Regional Policy Implications Concerning Coal Transportation
Impacts. The most serious particulates nonattainment difficulties
exist in the Detroit Metropolitan area.

3. Anticipated Programs for Managing Fugitive Dust Derived from Coal
.Transportation. Rules are presently under consideration which will
aid the state in achieving a means for appropriate controls of
fugitive dust resulting from coal transportation, handling, and
storage. These rules appear to be adequate for managing fugitive
dust problems with the exception that the rules do not specifically
provide for control of coal dust derived from wind blowing over the
tops of train cars.

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THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) OF 1969

The National Environmental Policy Act of 1969 represents the first
national declaration of a comprehensive environmental policy, as well as a
attempt to implement that policy by ensuring the consideration of
environmental values in administrative decision making. To this end, Section
102 of the Act contains "action forcing" provisions; provisions which seek to
ensure agency behavior within the mandate of NEPA by requiring these groups to
perform certain activities. Foremost among the provisions of section 102 is
the requirement for Environmental Impact Statements (EIS's) found within
Section 102(c). The primary purpose of the EIS is to provide full discussion
of all significant environmental impacts resulting from major federal actions
and to inform the public, as well as decision makers, of reasonable
alternatives which could serve to avoid adverse impacts or even enhance the
quality of the environment.

The requirements of Section 102 of NEPA may have a substantial effect
on projects related to coal transshipment in the coastal zone of Michigan.
EIS effects on the permitting process, with respect to facility development
and/or supplementary activities, may be substantial and should be identified.
Further., consideration of alternatives to various actions within EIS's may
influence factors such as facility location, technology employment, and
mitigation measures.

NEPA'S INFLUENCE ON AGENCY DECISION MAKING

As mentioned above, one of the main goals of NEPA was to involve the
consideration of environmental values in agency decision making. Rules
0
evolved pursuant to the act contain provisions constructed in an attempt to
ensure the accomplishment of that goal and include:

� the implementation of procedures under Section 102(2) (action forcing
procedures)

� identifying the major decision points within an agency's
environmentally related programs, and assuring that NEPA process
corresponds with them

� requiring relevant environmental documents, comments, and responses to
be part of the record during rulemaking or adjudicatory proceedings

� requiring that such documents as those mentioned above, accompany a
proposal through an agency review process

� requiring sufficient presentation and discussion of the full range of
project alternatives

Agencies involved in cases falling under the NEPA provisions are also
responsible for assuring that their decisions are carried out. Specifically,
rules promulgated pursuant to NEPA mandate that mitigation measures and other
conditions established in the environmental impact statement or during review,
and committed as part of any decision, shall be implemented by their lead

1-48

agency. In pursuit of this mandate, lead agencies shall take action such as
conditioning the funding of actions on the implementation of mitigation
measures; informing any cooperating or commenting agencies on progress in
carrying out mitigation measures which they have proposed and which were
adopted; making available to the public the results of relevant monitoring;
and perhaps most importantly, including appropriate conditions in grants,
permits, or other approvals.

NEPA's affect on the obtainment of the various permits which may be
necessary during the construction of a facility such as one involved in coal
transshipment can be substantial. Court decisions i-n @ases such as Calvert
Cliffs Coordinating Committee v. Atomic Energy Commission have held that the
issuance of permits and/or licenses to public as well as private entities can
in some cases require the completion of Environmental Impact Statements.
Environmental Protection Agency (EPA) argues that its environmental permit
programs, being "environmentally oriented anyway 11,2 should be exempted from
NEPA requirements, have led to numerous exemptions under various federal acts.
Due to such exemptions, specific pieces of Federal legislation in this area
which would require EIS's in all cases are virtually nonexistant. The
necessity of EIS completion is however determined on a case by case basis, and
may be required under certain Federal laws in some circumstances.

Under the Federal Water Pollution Control Act, the construction of a
facility of a type for which new source performance standards have been
proposed; which is classified as a "new source", and which is in a state where
the EPA administers the National Pollution Discharge Elimination System
(NPDES); will require the completion of an EIS. Federal EIS's for such
facilities are, however, not requirSd when a state has assumed responsibility
for the NPDES permit program, and as Michigan has assumed such
responsibility, would not be required for new sources in Mich4gan. No other
actions under the FWPCA would trigger the completion of an EIS.

Amendments to the Clean Air Act contained within the Energy Supply
and Environmental Coordination Act of 1974 excluded EPA's actions under the
Clean Air Act from the provisions of NEPA. Although this law did not exempt
industrial coal conversion from NEPA requirements, the Powerplant and
Industrial Fuel Use Act of 1978 dj)es exempt Department of Energy (DOE) ordered
conversions from the EIS process.

Under the provisions of the Federal Coastal Zone Management Act
state coastal zone programs must be approved by the Secretary of Commerce, and
EIS's are prepared for each program as it is submitted. Individual projects
falling under programs within this act would be the responsibility of state
agencies however, and would not reuqire federal EIS completion. It should be
noted however, that dredge and fill permits required frd)m the U.S. Army Corps
of Engineers would be subject to the provisions of NEPA.

Another piece of legislation which could potentially trigger the
completion of an EIS with respect to the obtainment of a federal permit would
be the Rivers and Harbors Act. Activities which could produce such by-
products as hazards to navigation, for example pier extensions or permanent
moorings, would require permits and could necessitate EIS's. Contacts within
the Corps of Engineers have stated, however, that, although environmental
assessments are carried out in virtually every case, very few EISs are
completed pursuant to the requirements of this act.
1-49

It should perhaps be noted that environmental assessm ents are carried
out for practically all coastal development projects in the absence of EIS's-
These assessments would, as would EIS's, include consideration of related
secondary impacts, such as the construction 'of rail spur lines serving coastal
facilities, when applicable. The general feeling among agency representatives
contacted seems to be that assessments are preferable to EIS's in that they
are less cumbersome and time consuming; possibly owing to the fact that they
do not include sections found in EIS's such as discussions of alternative
projects. EIS's are therefore generally conducted only in some of the
circumstances mentioned above, and when projects are of a controversial nature.

SOME IMPORTANT FEDERAL EIS DEFINITIONS AND COMPONANTS

Major Federal Actions

"Major Federal Actions," as defined under NEPA, include actions with
major effects which are subject to federal control and responsibility. Both
new and continuing activities are included under this definition, as are
projects and programs affected only partly by federal agency connections.
Federal actions tend to generally fall into one of the following groups:

� adoption of official federal policy such as rules, regulations,
treaties and international conventions or agreements, formal agency
policy documents, and agency interpretations adopted subject to the
Administrative Procedure Act.

� federally approved documents prescribing alternative uses of federal
resources

� adoption of programs enacted to implement a specific policy or plan, and

� approval of specific projects, such as construction or management
activities located in a specific geographic area. Projects include
actions approved by permit or other regulatory decision as well as
federally related activities.

Under this definition, many aspects of coal unloading and
transshipment projec 'ts could be considered major federal actions and would
require EIS's. Facility construction projects such as land clearing, access
road and rail spurline construction and various port development projects such
as pier or dock construction and dredging, would all probably fall within the
definition of major federal actions.

Lead Agencies

Where more than one Federal Agency is involved in a certain project,
NEPA requires the designation of a lead agency to supervise the preparation of
the Environmental Impact Statement. When disagreements between agencies
occur, the lead agency is to be determined by the following criteria:

e magnitude of agency involvement

1-50

� project approval/disapproval authority

� expertise concerning the actions environmental effects

� duration of agency's involvement, and

� sequence of agency's involvement

In certain cases, federal, state, or local agencies, including at
least one federal agency, may act as joint lead agencies.

The potential effect of the designation of a lead agency for any
given project should not be underestimated. Each agency brings with it a
particular constituency, set of objectives, and set of priorities. The
identity of the lead agency with respect to a coal transshipment project may
help determine what problems are identified, what studies are undertaken, what
alternatives are examined, and the nature of action on any necessary permits.

Alternatives

Based on the information and analysis contained in earlier parts of
EIS's, latter sections of EIS's should present the environmental impacts of
the proposal in question and any alternatives to the proposal in comparative
form. The general purpose of the alternative section is to prov-ide a sharp
definition of issues and options, thereby providing a clear choice among
options for decision makers. Specifically, the alternative section is to:

� explore and evaluate all reasonable alternatives and provide reasons
for elimination from study for those eliminated

� evaluate each alternative, including the proposed action in detail
sufficient to allow comparision

� include reasonable alternatives not within the jurisdiction of the lead
agency

� include the "no action" alternative

� identify the agency's preferred alternative, and

� include appropriate mitigation measures not already included in the
proposed action or alternatives

The alternative section of an EIS is perhaps the most important part
of the statement. This section provides an opportunity for the examination of
various solutions to a problem, inlcuding the "no action" alternative, and
compels agencies to justify choices made from among various options. This
part of an EIS may therefore yield the clearest exhibition of agency reasoning
and objectives, as applied in the evaluation of a proposal, and can be viewed
as a method of compelling agencies to account for their decisions.

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Finding of No Significant Impact (FONSI)

A FONSI is a document by a federal agency briefly presenting the
reasons why an action, not otherwise excluded, will not have a significant
effect on the environment and for which an environmental impact statement will
not therefore be prepared. It shall include at least a summary of the
environmental assessment; and shall note any other environmental documents
related to it.

NOTES

1. 449 F.2d 1109 (D.C. Cir. 1971)

2. Quarles, John, Federal Regulation of New Industrial Plants, Copyright 1979
by John R. Quarles, Jr., p. 196.

3. Ibid., p. 197.

4. 33 U.S.C. Subsection 1371 (c)(1).

5. Quarles, p. 197.

6. Ibid., p. 198.

1-52

MICHIGAN EIS REQUIREMENTS

Many state governments have enacted laws similar to NEPA which
require the completion of environmental impact statements. Michigan does
possess such a requirement, as outlined in Executive Order 1974-4 issued on
May 3, 1974 by Governor Milliken. Large facility development projects are
more likely to trigger the completion of a state EIS than a federal one, and
such statements may therefore exert a greater influence on administrative
decisions with regard to these projects.

The purpose, applicability, and structure of the Michigan EIS is
substantially similar to those required under NEPA. Executive Order 1974-4
requires broadly that:

all major activities of each agency of state government
having a significant possible impact on the environment or
human life be the subject of a formal environmental
assessment by the agency involved.

Specifically, EIS's shall be applicable to all major state activities
including:

(1) Policies

Any major policy, procedure, program or plan that sets a
definite course or method of action that will result in any
alteration or destruction of a significant element of the
state's resources, that would significantly alter existing
land use patterns and distribution of population, would
result in alteration of the maintenance and enhancement of
the long-term productivity of the state's natural resources,
or would propose to change the management of a resource. An
Environmental Impact Statement for any component of a program
that constitutes a major activity.

(2) Administrative Actions

Major administrative actions taken by state agencies
including: the issuance of licenses, permits or other forms
of approval and authorizations for the discharge of use of
materials that would result in significant degradation of
environmental quality; the granting of exceptions or
variances to rules or regulations, laws, administrative
orders or guidelines, including a failure to act, on the part
of an agency, where action is required by law, rule,
regulation or order, that would likely result in significant
degradation of environmental quality; the approval of
projects requiring land acquisition, disposition or leasing,
or construction that will utilize state funds inc 1 ud ing
grants-in-aid; the authorization of changes in land
utilization through exchange or use permits; industrial
development or expansion programs or actions; or changes in
administrative practices that would alter the management of

1-53

our natural resources base and/or the relationships of
portions of the base.

Under the guidelines of Executive Order 1974-4, state EIS's are to be
prepared whenever:

(1) Requested by the Governor

(2) The director of an agency determines that a proposed activity
may reasonably result in or create one or more of the
significant environmental effects listed under Part 4 A(l) -
(7) [of the Executive Order].

(3) An activity raises general public concern or controversy.

(4) Recommended by the Board after review of a "negative
declaration EIS" or abstract and a finding that public
concern or controversy exists or the proposed activity may
reasonably result in or create significant env ironmental
effects which warrant the preparation of an EIS.

(5) Requested by the Board as specified under Part 6 E (2) [of
the Executive Order].

"The Board" referred to above is the Michigan Environmental Review
Board (MERB) and is the entity responsible for the review of state EIS's with
the aid of the Inter-Departmental Environmental Review Committee (INTERCOM).
Executive Order 1974-4 makes it the responsibility of the MERB to recommend to
the Governor those actions of state agencies that should be suspended or
modified because of significant implications for the quality of the states
environment, or human life.

State legislation has not been exempted from EIS requirements the way
many federal programs have been. With respect to coal transshipment and
related projects, various state laws could trigger the completion of EIS's
pursuant to the granting of a permit or license. Specifically, the activities
covered by the Great Lakes Submerged Lands Act, the Inland Lakes and Streams
Act, the Wetlands Protection Act, the Great Lakes Shorelands Protection and
Management Act, and the Soil Erosion and Sedimentation Act could still require
the completion of EIS's under the guidelines of Executive order 1974-4.

Contact with the executive director of the Michigan Environmental
Review Board however, has indicated that few EIS's are completed pursuant to
these acts. The reason for this seems to be that state agencies have not
indicated that any projects requiring state permits contained impacts
significant enough to trigger the provisions of Executive Order 1974-4.
Assessments are still carried out in the determination of whether a state EIS
is necessary or not, much as are federal assessments, yet again are not as
extensive as EIS's. The MERB does keep track of any federal environmental
impact statements being prepared on Michigan projects, and does occasionally
provide comments on these statements, as well as notification of state
agencies when actions possibly requiring state EIS's come up.

1-54

SOME IMPORTANT STATE EIS COMPONANTS AND DEFINITIONS

Major State Activities - Any policy, administrative action, or project , as
described in Part 5A of these Guidelines, proposed by an agency of the
State of Michigan which could reasonably raise a question about any of the
following.

(1) A potential significant impact on the human environment that could
adversely affect the public health and welfare or could degrade the
quality of life.

(2) Alteration or destruction of a significant element of the human,
natural, amenity or historic resources of the state.

(3) Significant alteration of existing land use patterns.

(4) Significant alteration of population distribution of which would lead
to potential distribution changes.

(5) Significant impact on the maintenance and enhancement of the long-
term productivity of the state's natural resources.

(6) The imposition of an alteration to the ecological balance of a
significant element of the environment.

(7) Significant additional uses of energy resources or the acquisition
thereof.

Alternatives - A listing of alternative actions to achieve the project or
program objective, including: alternatives which cannot be effectuated by
the agency. Quantitative and qualitative descriptions of each alternative
in terms of both positive and negative economic and environmental impacts.
The alternative of "no action" should be considered.

Negative Declaration EIS - A concise series of statements, with
appropriate graphics, which describes an activity or action proposed by a
State agency, identifies any potentially adverse environmental effects and
public concerns or controversies that may occur as a result of the
proposed activity or action, defines the significance of the environmental
effects and public concerns or controversies and indicates that the
activity or action does not warrant the preparation of an environmental
impact statement.

EVALUATION

The environmental impact statement provisions of NEPA do not appear
to have in the past, nor do they promise to in the future, greatly affect coal
transshipment related projects in Michigan. Due to the extensive number of
exemptions to NEPA's provisions, permits arising from statutes which would be
expected to relate to coal transshipment most directly, often do not require
EIS's. Other federal statutes require state implementation of federally
outlined programs, and EIS's would be completed on the state level with
respect to these programs if at all. In actuality, representatives of the

1-55

Michigan Environmental Review Board indicate that very few EIS's are conducted
for projects related to our study area. Nevertheless, the framework for the
requirement of state EIS's does exist; and the many exemptions from the
requirements of NEPA which can be found in federal statutes are not present in
state statutes with respect to the guidelines of Executive Order 1974-4.
State environmental impact statements therefore may provide the best avenue
for the examination of such factors as project alternatives, which are found
in both federal and state EIS's, though generally not found in environmental
assessments.

1-56

LEVELS OF ALTERNATIVES

Though it appears that not many federal or state environmental impact
statements have been done for coastal facility projects in Michigan, the
consideration of alternatives within any EIS's which may be done in the future
will be important on both the federal and state level. Though the possible
range of and circumstances surrounding various coal transshipment related
projects is vast, there are some general alternative classes that would in
most cases apply.

0 The No-Project Alternative

Under provisions of both NEPA and Executive Order 1974-4 the alternative
of not undertaking any given project is to be considered in EIS
alternative sections.

0 Project Relocation

Adverse impacts may sometimes be avoided by an alternative project
location. In cases where such a result could possibly be gained by
relocation, this alternative should be considered.

Alternate Technologies

In any cases adverse impacts can be avoided by the employment of
technologies different from those initially proposed. Consideration of
alternate structural solutions should therefore be considered as possible
mitigation or prevention measures.

0 Comprehensive Mitigation Strategies

The development of a comprehensive mitigation strategy for the mitigation
of potential environmental impacts could provide an alternative to other,
perhaps more structurally oriented solutions to adverse impacts.

1-57

THE MICHIGAN ENVIRONMENTAL PROTECTION ACT

The Michigan Environmental Protection Act (MEPA) provides litigation
guidelines for court cases dealing with the states air, water, and other
natural resources. Specifically, MEPA expands the concept of standing for
cases brought under this Act (Section 2); requires a prima facie showing of
pollution or impairment by a plaintiff, which once made shifts the burden of
proof to the defendant for the remainder of the action (Section 3); provides
for temporary relief during administrative or judicial proceedings (Section
40) with retention of jurisdiction by the original court (Section 42) and
requires the consideration of the liklihood or extent of pollution,
impairment, or destruction of natural resources in all future administrative
actions (Section 5[21).

The provisions of MEPA clearly contain implications for the
transshipment of coal in Michigan's coastal zone. First of all, cases brought
alleging pollution impairment, or destruction of natural resources as a result
of coal related activities in Michigan will be litigated under the MEPA
guidelines. once a prima facie case has been established by a given
plaintiff, these guidelines can serve to place a rather heavy burden of proof
on alleged polluters; while also empowering the courts to grant injunctive
relief, possibly halting progress on coal related projects. Secondly, MEPA's
requirement for envionmental considerations in administrative licensing or
permitting procedures may effect the ease at which construction or development
projects pass through the state bureaucracy when necessary. In shore , the
provision of MEPA may slow coal development projects which present
environmental threats, and may force environmental impact mitigation in some
areas.

1-58

WATER POLLUTION CONTROL PROGRAMS

The following information discusses state water pollution control
programs concerning site construction, impervious materials, and coal
stockpile runoff controls.* Table 1 summarizes activities and facilities
necessary for coal transport and may also be used to show that *tAhe various
potential sources of water pollution are of nonpoint source origin.

Note that Table I suggests that a range of coal-based transport
facilities and activities may potentially impact several of the classical
physical, chemical and biological parameters of water quality including total
suspended solids (TSS), dissolved oxygen (DO), trace elements, toxic
substances, oil and grease, PH, and nutrients. For more extensive information
regarding water quality effects of land clearing, fugitive dust, spillage of
coal and other potential water pollution sources, please see this report's
environmental impact section.

A few general observations on achievement of cost-effective nonpoint
pollution management may be in order. First, there is the problem of
identifying, quantifying and modeling potential nonpoint source pollution
problems. For example, with respect to clal fines, other than studies
undertaken in the Duluth/Superior region, it appears that almost no
information is available on the potential water quality effects of coal
particulates***. This deficiency of information probably reflects perceptions
that environmental effects of coal transport are of relatively low priority in
funding for both nonpoint source problem research; and for research of coal
issues.

A second policy issue common to nonpoint source management relates to
the nature of institutional arrangements established under the 208 program.
Section 208 contains that FWPCA's major provisions requiring the state to
manage nonpoint source water quality problems. In Michigan, 14 economic

Other transportation, air quality, and dredge and dredge disposal may also
entail secondary benefits in maintaining water quality, however, these
sections are discussed elsewhere in this report.
Since the NPDES permit program for point source is the main means Congress
devised for restoring water quality, the FWPCA provides a definition of
point sources as follows: "... The term Ipoint source' means any
discernible, confined and discrete conveyance, including but not limited
to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure,
container, rolling stock, concentrated animal feeding operation, or vessel
or other floating craft from which pollutants are or may be discharged."
However, nonpoint source pollution was not defined by the Act, and
consequently has evolved operationally by a process of excluding point
sources. Of some assistance defining nonpoint source categories in and of
themselves, EPA in its 1975 program regulations indicated the term refers
to pollution that is:
1) Generated by diffused land use activities, not by identifiable
facilities
2) Conveyed to waterways through strong runoff or groundwater seepage and
3) Not susceptible to "end of pipe" treatment, but controllable by changes
in land practices.
See environmental impacts section.
1-59

development and planning regions have prepared initial 208 plans certified by
the governor and approved by the EPA Administrator. These regional planning
agencies do not have legal authorities for plan implementation. Instead, the
actual implementation of the 208 plan is normally achieved by state and local
entities, called "designated management agencies". Particularly where land
use controls are the most cost-effective approach to managing nonpoint source
pollution problems, it can be difficult to amend historic government roles and
attitudes in management of land use effects on water quality. Decisions with
respect to siting and design of industrial development (recognizing that
location and design is often the single strongest determinant in the extent
and severity of stormwater runoff) are decisions which largely remain the
prerogative of local government.

There are at least two general means by which more effective water
pollution control could be achieved by the state if necessary. One technique
which could be employed would be to reclassify certain problems traditionally
dealt with as nonpoint sources (e.g. stockpile runoff, land clearing, and
creation of impervious surfaces) mandating that they will henceforth be
treated as point source discharges. This redefinition of what constitutes a
point vs. a nonpoint source is based on the concept of collection and drainage
of pollution at readily identifiable discharge sources. NPDES permitting, in
other words, could be extended to necessitate the establishment of an
identifiable drainage network, such as point(s) of discharge and appropriate
treatment strategies sedimentation basins.

As a second method, if any of the constituents of coal were ever to
be classified as soluble toxic substances either by EPA or DNR toxic
substances control divisions, it would be necessary to consider more extensive
water pollution controls on coal transport and stockpiling.

Short of a) classifying coal as a carrier of soluble toxics, or b)
redefining runoff from coal piles etc. as point source pollution, programs
associated with water pollution derived from construction and operation of
coal transport facilities will continue to focus on nonpoint source management.
The major nonpoint source programs by activity are discussed below.

Site Preparation Controls

Act 347 of the Public Acts of 1972, the State Erosion and
Sedimentation Act, represents one of the first state-enacted statutes of its
kind in the nation. Under the Act, a landowner or developer who engages in an
earth change shall, prior to commencement of the change, obtain a permit for
any earth change which is a) 1 or more acres in size; or b) located within
500 feet of a lake or stream. Earth change, under the Act, is defined as a
man-made change in natural cover or topography of land, excluding the practice
of plowing and tilling for crop production.

Industrial development and transportation facilities are among the
construction activities and earth moving changes regulated where located
within 500 feet of a watercourse or where the total project area exceeds 1
acre. With the possible exception of expanded stockpiling at a site not
adjacent to a lake or stream, proposed coal transport facility developments
require an erosion and sedimentation permit.

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TABLE 1-6

SUMMARY OF POTENTIAL WATER POLLUTION
FROM COAL TRANSPORT ACTIVITIES AND INDENTIFICATION OF CURRENT REGULATORY FRAMEWORK

Activity Pollution Parameter(s) Control Program(s) Administering Agency

Site Preparation
Land Clearing TSS, DO - None
Earth Movement TSS, DO, trace elements - Soil Erosion and Sedimentation Act - Michigan DNR or local.
toxics entity for DNR

Creation of
Impervious Surfaces
TSS, oil and grease, *also problems may be addressed 208 Desighated Mgmt.
trace elements, toxics as part of the 208 Planning Agency and other local
Process entities.
Coal Stockpiling
Stormwater
Runoff TSS , possible trace - Potential for addressing problems- with - local entity
elements, ph the 208 Planning Process
H Fugitive Dust TSS , possible trace - Fugitive dust source problems can be - Michigan DNR
elements, ph addressed under the Air Quality Imple-
mentinion Plan
Coal Transportation
- Problems arising from fugitive coal dust - Michigan DNR
- Fugitive dust within the Air Quality Implementation Plan
- Spillage TSS, ph, trace
- Engine Emissions elements, CO. - Spillage of coal is not currentlv regulated - None
NO, CH
operation of Ships
Vessel conduct - Resuspension of TSS - Potential under Federal Ports and
toxics, nutrients, Waterways Act, No enforceable USCO Regs.
trace elements U.S. Coast Guard
Sanitary wastes - bacteria, TSS, DO - Regs. against oily bilge discharge
Spillage - TSS, trace elements, (33CFR 155)
ph - spillage not regulated

Harbor Maintenance
Dredging - Resuspension of TSS, - FWPCA Section 404 Dredge and Fill U.S. Corps of Engineers
toxics, nutrients, Provisions Michigan DNR
trace elements jointly administer
Dredge Disposal - Leaching of toxics, - State Submerged Lands Acts (3)
trace elements, TSS - Shorelands Protection and Management
Act

Earth changes under the Act, must be conducted in a manner which
effectively minimizes the occurrence of accelerated soil erosion. This
objective requires the permit applicant to prepare a soil erosion and
sedimentation plan identifying control measures to be utilized during the
duration of the project.

The Natural Resources Commission is authorized to delegate state,
county or local implementing agencies for implementation of the Soil Erosion
and Sedimentation Act. Rules of administering agencies may be more
restrictive than the Act and state implementing regulations, but may not make
lawful that which is unlawful.

The Soil Erosion and Sedimentation Act has already been evaluated by
the Great Lakes Basin Commission as part of the regional Water Quality Plan.
Appendices of the adopted Water Quality Plan, indicate that the Act represents
a workable framework. However, the plan also concludes that weak enforcement
due to inadequate staff represent major imp5diments to achieving the Act's
objectives concerning construction activities.

Controls on Creation of Impervious Surfaces

Once compliance with provisions of the Soil Erosion and Sedimentation
Act has been assured, the applicant need be concerned only with local land
use regulations. (See Zoning ordinance section) Creation of impervious
surfaces will not be specifically regulated in most cases, however, if
property is to be used for industrial purposes, the proposed use will need to
comply with local zoning codes pertinent to the property.

The Great Lakes Basin Commission's adopted Water Quality Plan
indicates that enabling legislation for local zoning codes does not contain
adequate provisions which address environmental impacts of land use, including
effects of stormwater runoff from urban areas. _ In addition to problems
within the enabling legislation, it should be indicated that lack of state
judicial or legislative standards for guiding local rezoning decisions may
pose limitations for use of zoning as a reliable environmental management
technique. 4-

Coal Pile Runoff Controls

As previously suggested, Section 208 Water Quality Planning
represents one of the chief mechanisms for evaluating and managing nonpoint
source problems. However, while it was intended that during the course of
developing the initial 208 policies specific recommendations for control
strategies would be developed, this has not proven to be the case. Plan
recommendations "instead are primarily non-inter and deal
with additional planning, analysis, and so forth. ,yentive in nature

According to sources contacted, nonpoint source controls on coal pile
runoff, including sedimentation basins, have not yet been required - except
possibly in isolated cases by local ordinances - for either existing or
proposed new stockpile facilities. However, DNR does attempt to encourage
runoff controls as part of its evaluation of new proposals, and promotes the
use of sedimentation 6 @asins for coal runoff in conjunction with basins
necessary for fly ash. '
1-62

FINDINGS

1. Water Quality Impacts. A wide range of water pollution problems may be
aggravated by coal unloading and storage, but relatively little is known
about the seriousness or magnitude of these problems.

2. Scope of Policy Description. Information contained in this section is
pertinent to the following sources of water pollution emanating from
coal-based transportation: site preparation, creation of impervious
surfaces, and coal pile runof f . Effects on water quality of
transportation, dredge and disposal of spoils, and air quality are
addressed in other sections of this report's policy assessment.

3. Nonpoint Source Origin of Impacts. Water pollution from coal
transportation based activities are widely perceived as constituting
nonpoint source problems. Conceptually it is forseeable that either a)
soluable constituents of coal may be placed on toxic or other critical
materials lists; or b) specific coal transportation based activities may
eventually warrant treatment as point source pollution activities. if
either charge were to be promulgated in the future under state or
federal regulations, more stringent management of water pollution
resulting from coal-based transportation could be anticipated.

4. Site Preparation. The Soil Erosion and Sedimentation Act have been
summarized by the Great Lakes Basin Commission as part of the regional
Water Quality Plan. The Water Quality Plan notes that the Act
represents a workable framework, however inadequate staff and weak
enforcement have been recognized as major impediments to achieving the
Act's objectives concerning construction activities.

5. Creation of Impervious Surfaces. The Great Lakes Basin Commission's
Water Quality Plan indicates that enabling legislation for. local zoning
codes does not contain adequate provisions which address environmental
effects of stormwater runoff from urban areas. In addition, it should
be indicated that a general lack of state journal standards for guiding
rezoning decisions may also pose practical limitations for use of zoning
for environmental management purposes.

6. Coal Pile Runoff. Nonpoint source controls on coal pile runoff,
including sedimentation basins, have not yet been required for either
existing or proposed new stockpile facilities. However, DNR does
attempt to encourage runoff controls as part of its evaluation of new
proposals, and promotes the use of sedimentation basins for coal pile
runoff in conjunction with the basins necessary for fly ash.

1-63

FOOTNOTES
1 Weston Environmental Consultant s-Des igners, Coal Transshipment Facility,
Superior, Wisconsin, 1974.

2 Great Lakes Basin Commission, Water Quality P,lan, November, 1979, page 84
3 Ibid., page 83
4
Inman, Don, Environmental Enforcement Division, DNR, communication, June
17, 1980
5 Southeast Michigan Council of Governments, Fi-nancial. and Economic Impacts
of Plan Recommend-at-ions, March, 1978
6 Howard, Alan5 Point Source Studies Section, Environmental Services
Division, DNR, private conversation, June 23, 1980.
7 Bek, Chang, Engineering and Technical Services, Water Quality Division,
DNR, private conversation, June 23, 1980.

1-64

DREDGING AND DISPOSAL OF DREDGED MATERIAL

Introduction

The U.S. Army Corps of Engineers and the Department of Natural
Resources serve as joint reviewing agencies permits for dredging and dredged
materials disposal into navigable waters when undertaken by public and private
entities. The Corps' regulatory authority, to be discussed, is historically
grounded in the Rivers and Harbors Act of 1899 and also the Federal Water
Pollution Control Act (FWPCA) of 1972. In addition, the Corps is charged by
law with maintaining the navigable waterways of the United States.

The role of other federal agencies, including the EPA, U.S.Fish and
Wildlife Service, and the State DNR in dredging and dredged material disposal,
are also discussed in the following sections.

It should be readily apparent that coal is not the only commodity in
Great Lakes waterborne commerce. Therefore, this analysis recognizes that
coal transport by vessels, like other waterborne commerce, is dependent on
dredge and disposal programs. Therefore, the analysis offers background
material and specific recommendations which are intended to assist in
accomodating increased coal transport consistent with environmental and
economic objectives.

Federal Responsibilities for Dredging and Materials Disposal

The Corps of Engineers must deal with two categories of dredging and
dredged material disposal projects: projects by the Corps which represent
Federal commitments for improvement and maintenance of navigable waters and
administration of permit programs for dredging, dredged material disposal and
associated activites. These Corps responsibilities were summarized below.
Civil Works Activities

With.in the state of Michigan, tDe Corps itself has constructed or
provides 9f intenance for 64 projects, 23 of which provide commercial
navigation. In addition, the Corps routinely processes Section 10 and
Section 404 permits necessary for a wide range of purposes including
recreational boating and commercial navigation.

See projections for discussion of current and future anticipated volumes of
transportation for coal by water and by other modes.

1-65

Regulatory Authorities

The Corps of Engineers exercises regulatory authority in navigable
waters of the United States under Sections 9, 10, and 14 of the Rivers and
Harbors Act of 1899. Under Section 10, Corps of Engineers permits are
required a) for virtually all excavation work within U.S. navigable waters; b)
for discharge of dredged material or fill into navigable watets; and c) for
placement of structures such as piers, wharves, docks, riprap and groins in
areas of navigable waters.

In adopting the Section 404 provisions of the Federal Water Pollution
Control Act, the Corps' regulatory authority over discharge of dredged or fill
material into waters was again established. The purpose of the 404 program is
to insure that the chemical and biological integrity of water is protected
from irresponsible discharge of fill material. The principle differences
between the Section 10 and Section 404 provisions is that 404 only regulates
placement of fill and dredged material while section 10 applies to a broider
range of activities without regard to whether there has been a discharge. A
discussion of dredging project review procedures follows.

Dredging Project Review Procedures

With respect to the administration of dredging and dredged material
programs, three major pieces of federal environmental legislation have been
adopted which have greatly affected the Corps administration 4 of both its
regulatory and its capital improvements and maintenance programs.

The first of these, the Fish and Wildlife Coordination Act o 'f 1958
was adopted as a consequence of concern over destruction by dredging and
filling of aquatic nursery and feeding areas. The Act provides that whenever
the waters of "any stream or other body of water are proposed or authorized to
be impounded, diverted, the channel deepened, or the stream or other body of
water otherwise controlled or modified for any purpose whatever by any
department or agency of the United States, or by any public or private agency
under federal permit or license, such department or agency must first consult
with the United States Fish and Wildlife Service, Department of the Interior,"
as well as the applicable state agency, "with a view to the conservation of
wildlife resources by preventing loss of and damage to such resources as well
as providing for the development and improvement thereof in connection with
such water resource development" [P.L. 85-6241

The second significant legislation amending activities of the Corps
(and other Federal agencies) was the National Environmental Policy Act ?f
1969. NEPA specified that prior to initiation of any major Federal action ,
the responsible agency must prepare a detailed environmental impact statement.
The statement prepared must include identification of the following: 1) the
environmental impact of the proposed action; 2) any adverse environmental
effects which cannot be avoided should the proposal be implemented; 3)
alternatives to the proposed action; 4) the relationship between local
short-term uses of man's environment and enhancement of long-term
productivity; and 5) any irreversible and irretrievable commitments of
resources which would be involved in the proposed action should it be
implemented." (P.L. 91-190, Section 102).

1-66

The third major legislative change, the 1970 Rivers and Harbors Act
of 1970 (P.L. 91-611), authorized the Corps to build, operate, and maintain
confined disposal facilities for contaminated dredged materials on the Great
Lakes and their connecting channels. This Great Lakes Confined Disposal
Program requires the Corps to place behind retaining dikes all dredged
material which EPA determines is contaminated (P.L. 91-611, Section 123). The
law also authorized the Corps to conduct a research program on the effects of,
and alternatives to, current dredged material disposal methods.

Section 123 of the Rivers and Harbor Act of 1970 (P.L. 91-611)
requires EPA to assist the Corps of Engineers in administering the Great Lakes
Confined Disposal Program. EPA, under this law, is responsible for
establishing standards used for determining degree to which dredged sediment
is contaminated . As noted previously, when dredged material exceeds EPA
pollution standards, by law the material must be placed behind containment
dikes.

Section 123 together with Section 404 of the Federal Water Pollution
Control Act Amendments of 1972 (P.L. 912-500) and Section 103 of the Marine
Protection, Research and Sanctuaries Act of 1972 (P.L. 92-532) all require
that EPA, in conjuction with the Corps, must establish and apply guidelines
for the discharge of dredged materials into inland and ocean waters. T h e s e
acts have substantial impact on dredge and disposal programs because they give
EPA, rather thAn the Corps, the final authority as to where dredged material
can be dumped. U-

STATE RESPONSIBILITIES FOR DREDGING AND MATERIALS DISPOSAL

The basis for state regulation of dredging and dredged materials
disposal is derived form the major shorelands and waterways state statutes
including the Great Lakes Submerged Lands Act (PA 247 of 1955), the Inland
Lakes and Streams Act (PA 346 of 1972), the Shorelands Protection Act (PA 245
of 1970), and (after October 1980) the Geomaere-Anderson Wetland Protection
Act (PA 203 of 1979), all discussed at length in other portions of this report.

For administering provisions of these Acts as they pertain to
dredging and materials disposal, the state has established its own advisory
committee. The committee, called the Dredge Spoils Committee, includes
representatives from various state agencies for the purpose of providing
technical assistance for DNR and the Corps concerning dredged material
disposal plans.

State permitting authorities extend to federal civil works projects,
particularly in cases where the state can identify project in%onsistency with
a portion of the approved coastal zone management program. Through its
coastal zone program, the state of Michigan has worked with the Corps to
provide for dredging activities that are consistent with the state's program.

Under a memorandum of understanding between Michigan DNR and the
U.S.Corps of Engineers, the state's Dredge Spoils Committee does provide the
Corps with a review of the proposed project which indicates degree of proposal
compliance with state laws and policies. Consequently, at present the Corps
and Michigan DNR jointly process permit applications for all dredging and
disposal projects within the state.
1-67

It should be noted that under the Federal Water Pollution Control
Act, states are authorized to establish administering programs for regulating
discharges of pollutants into the navigable waters. Michigan has already been
certified by EPA as responsible for issuance of NPDES (Section 402) point
source discharges.

However, the state certified program and Section 402 provisions in
general, do not include jurisdiction over dredged materials disposal.

If the state's dredged material program were to be approved by EPA as
meeting administrative Section 404 standards, state permits would be issued in
lieu of joint federal-state permit administration. interest has been
expressed by state officials in such an arrangement, however, program
certification is not pending at this time. Detroit District Corps officials
have cautioned that state responsibility for permitting dredging and dredged
disposal programs may not occur for some time. Nevertheless, the state has
made progress towards creating tbf type of program which could qualify as
acceptable under Federal standards.

1-68

EVALUATION

Types of Dredging Projects
1. Two categories of dredging and dredged material disposal projects
have been recognized in this report: projects by the Corps which
represent federal commitments to maintenance of navigable waters; and
projects by all other agencies and individuals which require permit
approval.

Number of Civil Works Projects
2. Within the state of Michigan, the Corps provides maintenance for more
than 64 navigation projects, of which 23 provide for water-borne
commerce.

Maintenance of Existing Projects
3. As funds for federal projects becomes more limited, maintenance of
existing Corps projects is likely to receive priority over initiation
of new projects.

identification of Initial and Maintenance Dredging Requirements
4. Dredging requirements necessary to support water-borne coal delivery
may include the following: a) initial dredging for accomodating site
delivery; and b) increased maintenance necessary for removal of
channel sedimentation resulting from fugitive coal dust, runoff from
coal piles, and resuspension of sediments caused by vessel
operations.

Long-term Material Disposal Planning Needs
5. Where increased harbor delivery of coal is forecasted, additional
confined dredged material disposal may be necessary. In instances
where capacity of existing and planned confined disposal sites is
constrained, it may be appropriate to encourage long-term disposal
site acquisition and materials disposal planning prior to permit
approvals.

State Responsibilities for Project Review
6. State administration of Section 404 FWPCA permits is a theoretical
possibility once the state establishes an adequate regulatory
framework. Presently the state has dredging and filling statutory
provisions and has also made arrangements with the Corps for joint
administration of permit applications.

1-69

FOOTNOTES

1 Rogers, Environmental Law, page 399.
2 Schoof, Carl, Corps of Engineers, Detroit District . Operations and
Maintenance Branch, Phone interview, July 22, 1980.
3 Billmaier, Donald L., Corps of Engineers, Detroit District. Chief,
Operations and Maintenance Branch, Phone interview, July 2, 1980.
4 General Accounting Office, "Dredging America's Waterways and Harbors -
more information Needed on Environmental and Economic Issues",
CED-77-74, June 28, 1977
5 The GAO in its report entitled Dredging America's Waterways and Harbors
indicates that the Corps has established an internal policy not to
perform maintenance dredging without preparation of an EIS. This
decision reportedly was made in response to a) guidelines published
by the Council of Environmental Quality and b) a 1974 court decision.
Since January 1, 1976, according to GAO the Corps has opted to
prepare EIS statements for both new construction and maintenance
dredging projects.
6 ibid, page 11.
7 Haywood, David, Chief of Land, Lake & Stream Protection Section,
Personal interview, June 17, 1980.
8 GAO, Dredging America's Waterways and Harbors, page 12.
9 Billmaier, Donald L., phone interiew

1-70

STATE SUBMERGED LANDS LEGISLATION

Three state acts are discussed in the following sections each dealing
with permit requirements for use of submerged lands and wetlands. These acts
are discussed in order of their adoption by the state legislature. They are:
the Great Lakes Submerged Lands Act (P.A. 247 of 1955), the Inland Lakes and
Streams Act (P.A. 346 of 1972) and the Geomaere-Anderson Wetland Protection
Act (P.A. 203 of 1979).

A single evaluation of these acts is presented in concluding remarks.

GREAT LAKES SUBMERGED LANDS ACT

Public Act 247 of 1955 applies to bottomlands and waters of the Great
Lakes within the boundaries of the state. These bottomlands include bays and
harbors lying below and lakeward of the ordinary high water mark. In most
cases these lands belong to all the citizens of Michigan and, even where such
lands have been sold, leased or otherwise granted to private interests, the
state generally maintains a vested interest in protection of certain natural
resource and public use of navigable waters. The Great Lakes Submerged Lands
Act, Public Act 247 of 1955, provides a measure for the protection of these
public interests.

In instances where dredging, filling or construction activities would
involve use or alteration of the Great Lakes bottomlands, a permit for the
activity is required. The Department of Natural Resources, acting on behalf
of the state, is authorized to issue a permit only after finding that the
proposed activity "will not substantially affect the public luse thereof for
hunting, fishing, swimming, pleasure boating or navigation...'

Additional provisions are incorporated into the Great Lakes Submerged
Lands Act which permit the Department of Natural Resources to enter into
agreements which provide for sale, lease, exchange or other disposition of
bottomlands. Prior to approving such agreements, the Department must find
that the sale, lease or exchange of bottomlands 2will not impair the public
trust in bottomland and waters of the Great Lakes.

Implementing regulations for the Great Lakes Submerged Lands Act
provide for coordination of t@e following government agency approvals to
accompany the permit application :

(a) Action by the United States Corps of Engineers shall be in
permit or letter form to the applicant and shall indicate the
consent or nonobjection of the corps from the standpoint of
federal navigation.

(b) Approval by the State Waterways Commission shall be in letter
form to the applicant and shall indicate the consent or
nonobjection of the commission.

(c) Approval by a local unit of government shall be in the form of
a certified copy of a resolution of its legislative body.

1-71

Within the implementing regulations, additional language was adopted
by the Natural Resources Commission re-emphasizing that the Department shal
consider public interest and public trust when reviewing permit applications.
In addition rules indicatf that the Department concerns shall include
maintenance of the shoreline.

Therefore, collectively, criteria for approval of Great Lakes
Submerged Lands applications indicate that public interest and public trust
shall be considered in the following areas: navigation, hunting, fishing,
swimming, pleasure boating and maintenance of the shoreline. Hunting and
fishing concerns logically permit the Department to consider effects of the
application on recreational opportunities and habitat considerations.

INLAND LAKES AND STREAMS ACT

Public Act 346 of 1972, the Inland Lakes and Streams Act, provides
for protection of connecting Great Lakes channels including the St. Marys, St.
Clair and Detroit Rivers, as well as inland lakes, streams and surface water
areas of greater than 5 acres. The Inland Lakes and Streams Act specifically
does not cover the Great Lakes and Lake St. Clair (which are under
jurisdiction of the Great Lakes Submerged Lands Act) as well as those lakes
and ponds with a surface area of less than 5 acres (under the Act such
watercourses remain unregulated).

Within submerged lands areas covered by the Inland Lakes and Streams
Act, a permit is required for various activities, including: dredge or fill
of bottomland, placement of a structure on bottomland, and construction of a
connecting artificial waterway.

The Department of Natural Resources, under the Statute

11shall issue a permit if it finds that the
structure or project will not adversely affect
the public trust or riparian rights. In passing
upon an application the department shall consider
the possible effects of the proposed action upon
the inland lake or stream and upon waters ... and
the uses of all such waters, including uses for
recreation, fish and wildlife, aesthetics, local
government, agriculture, commerce and industry.
The department shall not grant a permit if the
proposed project or structure will unlawfully
impair or destroy any of the watgrs or other
natural resources of the state."

1-72

Implementing regulations for the Inland Lakes and Streams Act
elaborate on criteria for permit approval, and are more specific than the
implementing regulations for the Great Lakes Submerged Lands Act. still,
considerable flexibility is evident in the Inland Lakes and Streams Acts
implement ing sA andards. Prior to permit issuance, DNR shall determine all of
the following:

(a) That the adverse effects to the environment and the public
trust are minimal and will be mitigated to the extent
possible;

(b) That the resource affected is not a rare resource;

(c) That the public interest in the proposed development is
greater than the public interest in the unavoidable
degradation of the resource;

(d) That no feasible and prudent alternative location is
available.

GEOMAERE-ANDERSON WETLAND PROTECTION ACT

Public@ Act 203 of 1979 covers wetlands, bogs, swamps and marshes
which support aquatic or wetlands habitat and which is any of the following:

(1) Contiguous to a lake, pond, river or stream;

(2) Not contiguous but more than 5 acres (except for counties of
less than 100,000 population until completion of a wetlands
inventory); or

(3) Not contiguous and less than 5 acres if DNR determines that
protection is essential and has so notified the owner.

1-73

After October 1980, the Act requires a permit from the DNR for
essentially of the preceding wetlands areas. Uses of wetlands requiring a
permit before initiation include drainage of &urface water, structural
development, dredging and placing of fill material.

Implementing regulations for the Wetlands Act are currently being
developed. It should be noted that in adopting the Wetlands Act, the
legislature approved a relatively specific statute compared to the Great Lakes
Submerged Lands and Inland Lakes and Streams Act particularly with respect to
what criteria shall be used by the DNR in administration of the Act. The
extensive criteria for approval of permits are outlined below:

(1) The DNR shall consider the following values of
wetlands as part of the criteria for administering
the Act**:

(a) Wetland conservation is a matter of state
concern since a wetland of 1 county may be
affected by acts on a river, lake, stream, or
wetland of other counties.

Note the following exceptions:

1. Certain specified uses are allowed in a wetland without a permit
[Section 6(2)1, the range of uses exempted imply that transportation
and coal stockpiling activities would require a wetlands permit
located within wetlands covered by this act.

2. Specifically exempted from provisions of the Wetland Protection Act
or activities requiring a permit under the Great Lakes Submerged
Lands Act or Inland Lakes and Streams Act. In other words, the
Wetlands Protection Act does not replace or otherwise affect the
jurisdiction of earlier submerged lands legislation. [Section 6(l)].

3. Finally, after federal approval of a state program under Section 404
of the Clean Water Act of 1977 (see this report dredging and dredged
material disposal section) where a project solely involves the
discharge of fill material subject to the approved state 404 program,
an additional permit shall not be required by this act. [Section
60)]

This list serves the function of permitting the DNR to consider or
broad range of state interests and public values for wetlands
conservation. These values of wetlands are called criteria by the
Wetlands Protection Act, however in all fairness, they can serve as
criteria only in conjunction with the Act's other standards for project
proposal review.

1-74

(b) A loss of a wetland may deprive the people of
the state of some or all of the following
benefits to be derived from the wetland:

M Flood and storm control by the hydrologic
absorption and storage capacity of the
wetland.
(ii) Wildlife habitat by providing breeding,
nesting, and feeding grounds and cover for
many forms of wildlife, waterfowl, including
migratory waterfowl, and rare, threatened, or
endangered wildlife species.
(iii) Protection of subsurface water
resources and provision of valuable watersheds
and recharging ground water supplies.
(iv) Pollution treatment by serving as a
biological and chemical oxidation basin.
(v) Erosion control by serving as a
sedimentation area and filtering basin,
absorbing silt and organic matter.
(vi) Sources of nutrients in water food
cycles and nursery grounds and sancturaries
for fish.
(c) Wetlands are valuable as an agricultural
resource for the production of food and fiber,
including certain crops which may only be
grown on sites developed from wetland.
(d) That the extraction and processing of nonfuel
minerals may necessitate the use of wetland,
if it is determined that the proposed activity
is dependent upon being located in the
wetland, and that a prudent and feasible
alternative does not exist.

(2) A permit shall not be approved unless the DNR determines
that: a) the permit is in the public interest; b) that the
permit is necessary to realize benefits derived from the
activity; and c) that the activity is otherwise lawful.

(3) In determining whether the activity is in the public
interest, the benefit which reasonably may be expected to
accrue from the proposal shall be balanced against the
reasonably foreseeable detriments of the activity. The
decision shall reflect the national and state concern for the
protection of natural resources from pollution, impairment,
and destruction. The following general criteria shall be
considered:

(a) The relative extent of the public and private need for
the proposed activity.

1-75

(b) The availability of feasible and prudent alternative
locations and methods to accomplish the expected
benefits from the activity.
(c) The extent and permanence of the beneficial or
detrimental effects which the proposed activity may have
on the public and private uses to which the area is
suited, including the benefits the wetland provides.
(d) The probable impact of each proposal in relation to the
cumulative effect created by other existing and
anticipated activities in the watershed.
(e) The probable impact on recognized historic, cultural,
scenic, ecological, or recreational values and on the
public health or fish or wildlife.
M The size of the wetland being considered.
(g) The amount of remaining wetland in the general area.
(h) Proximity to any waterway.
M Economic value, both public and private, of the proposed
land change to the general area.

(4) In considering a permit application, the department shall
give serious consideration to findings of necessity for the
proposed activity which have been made by other state
agencies.

(5) A permit shall not be issued unless it is shown that an
unacceptable disruption will not result to the aquatic
resources (as determined pursuant to items I and 3).

(6) A permit shall not be issued unless the applicant also shows
either of the following:

(a) The proposed activity is primarily dependent upon being
located in the wetland.
(b) A feasible and prudent alternative does not exist.

1-76

EVALUATION

1. In general the adopted submerged lands legislation (Great Lakes
Submerged Lands Act, Inland Lakes and Streams Act and Wetlands
Protection Act) can be interpreted as requiring a state-issued permit
for virtually any coal tansport or storage proposal involving wetlands
or submerged lands within the Great Lakes, inland streams or rivers,
and most other wetlands of greater than 5 acres.

2. Language adopted by the legislature in passage of the recent Wetlands
Protection Act represents improvements in state management of natural
resources with respect to the geographic areas where the state has
determined that resource management programs are needed. The Act's
language provides fairly specific language for use by the administering
agency in review of proposed projects.

3. The Inland Lakes and Streams Act and Great Lakes Submerged Lands Act
remain in effect. many (if not most) project proposals for coal
transportation activities will continue to fall under the jurisdiction
of the Inland Lakes and Streams and Submerged Lands Act.

4. The continued development of specific guidelines - perhaps modeled in
part after the legislature's Wetlands Protection Act criteria - would
probably improve the Inland Lake and Stream and Submerged Lands Act for
both the department and for other interested parties of all types.
Some of the language of the Wetlands Protection Act which may merit
attention by the Natural Resources Commission and state legislature in
considering future amendments include the following:

a. Is the proposed activity primarily dependent upon being located in
a submerged lands or wetlands area?

b. Has serious consideration been given to findings of necessity for
the proposed activity mode by other (state) agencies?

C. What is the probable impact of the proposal in relation to
cumulative trends resulting from area land use changes?

d. What is the public need for the proposed activity?

5. Since the three separate acts deal with submerged lands areas and
require permits for basically the same set of potential uses, they
should be administered in a coordinated manner.

1-77

THE SHORELANDS PROTECTION AND MANAGEMENT ACT

Public Act 245 of 1970, the Shorelands Protection and Management Act
contains procedures for the designation of specified land areas and for
regulation of land uses within three categories of Great Lakes shorelands:
(1) environmental areas, (2) areas prone to high risk erosion, and (3) areas
within the 100-year floodplain. The Act institutes what is probably the
single most comprehensive state land use legislation pertaining to management
of Great Lakes shoreland in that the Act is intended to prevent needless
destruction of critical shoreland habitat and also provides measures for
consumer protection. Substantive requirements of the Act vary according to
shoreland category, the following discussion covers each of the land
categories recognized by the Act.

Environmental Areas

As defined in the Shorelands Protection and Management Act, "an
environmental area is an area of the shoreland determined by the department. 11
to be necessary for the preservation and maintenance of fish and wildlife.
To be eligible for departmental designation as an environmental area, property
must lie within 1,000 feet landward of the ordinary high water mark of the
Great Lakes or a connecting waterway. Also eligible are lands adjacent to
waters affected by levels of the Great Lakes.

Under regulations promulgated by the state Natural Resources
Commission, the following shorelands uses in designated environmental area
shall require a permit from the department or from a local government agency
pursuant to state approved local ordinance:

1) Dredging, filling, grading or other soil alterations;
2) Placement of permanent structures;
3) Modifications of natural drainage, except that reasonable care and
maintenance of established drainage improvement works is not
regulated; and
4) Alteration of vegetation utilized by fish and wildlife for spawning,
nursery, feeding, migration, and other purposes (except that timber
harvest is generally not regulated unless the site involves a
colonial bird nesting area)

Under the adopted regulations, the preceding activities, if proposed
for a designated environmental area, would require a state permit or a local
permit issued pursuant to a state-approved ordinance. In cases where an
approved local ordinance does not exist, the Act's implementing regulations
provide that a permit application from the state shall be approved if both of
the following conditions are satisfied:

A) Adverse effects to fish and wildlife habitat are minimal and have
been mitigated to the maximum extent feasible; and
B) No feasible and prudent alternative to the proposed plan is
available.

1-78

EVALUATION

1. Areas designated as environmental areas under the Shorelands
Protection and Management Act tend.to be wetlands or marshes but also
includes some uplands and islands. Of over 2,000 miles of Great
Lakes shorelands, as of May, 1978, approximately 100 miles had been
designated as environmental areas. Approximately,35 additional miles
have been added from May 1978 to July 1980." Ultimately, the
Department goal @s to consider environmental areas designation for
around 300 miles.

2. It is generally acknowledged that the Shorelands Protection and
Management Act represents one of the most useful provisions available
for conservation of designated shorelands environmental resources.

3. If proposed for a designated shorelands environmental area, coal
stockpiling and transportation facilities, together with associated
industrial development, are not likely to be found compatible with
purposes of the environmental designation. It is safe to assume that
coal-oriented facilities will not (and should not) be located within
designated environmental areas.

4. Formal project review mechanisms have not been established for
considering environmental impacts of coal handling facilities where
such facilities are proposed for sites adjacent to (or otherwise
impacting) designated environmental areas.

5. Shoreland areas not designated as a critical environmental area may
still contain important environmental values, including critical
habitat for fish and wildlife. A mechanism for state review for
shorelands project development for such sites has n ot yet been
established, a shorelands project, however may require review under
other state statutes such as the Soil Erosion and Sedimentation Act
and Great Lakes Submerged Lands Act.

Areas Prone to Erosion

A "high-risk [erosion] area" is defined in the Act to be shorelands
area determined by the department to be subject to erosion. Regulation
promulgated by the Natural Resources Commission specify that the department
shall designate high-risk areas where the department finds "that bluffline
recession has been occurring at an average annual rate of 1.0 foot or greater
per year, based on a minimum period of 15 years."

Of over 2,000 miles of Great Lakes mainland shoreline (excluding
islands), the state has approximately 400 miles of shoreland which can be
classified Is high risk erosion areas, of which about 225 miles are currently
designated.

Regulations promulgated by the Natural Resource Commission require
the department to designate a minimum required setback from the bluffline in
all designated high risk erosion areas. This setback is intended to provide a
projected 30-year erosion zone. Permanent structures are not to be permitted
within the required setack except under special circumstances where a parcel

.1-79

has been established prior t@ high-risk area designation and after additional
criteria have been satisfied.

EVALUATION

1. Of approximately 400 shoreline miles which have been recognized as of
November 1979 as containing features which qualify the shoreland as a
high-risk erosion area, only 197 miles were designated as of May 1978
and 225 miles as of July 1980.

2. Complete implementation of provisions of the Shorelands Protection
and Management Act pertaining to measures for high-risk erosion areas
which have already platted or improved has proven more difficult than
implementation of protective measures for undeveloped lands.

3. A shoreline characterized by eroding bluffs is unlikely to qualify as
potential water-related prime industrial development areas, which
suggests that conflicts between coal handling facilities and
designated high-risk erosion areas will be minimal.

4. Any new coal transportation facility sites within designated
higb-risk erosion areas will need to comply with required setbacks.

Flood Risk Areas.

As defined in the Shorelands Protection and Management Act, "flood
risk area" means the area of the shoreland which is determined to be subject
to flooding from effects of levels of the Great Lakes and is not limited to
1,000 feet. Implementing regulations further define the area of flood risk to
be any area within the 100-year floodplain of a Great Lake or connecting
waterway (as identified in an approved floodplain delineation study).

Under the Shorelands Act implementing regulations, 11new
nonresidential structures in a (designated) flood risk area shall have the
lowest floor, including basement, not lower than the elevation defining the
flood risk area, or together with attendant utility and sanitary facilities,
be certified by a professional engineer or architect to be destgned so that
below the elevation defining the flood risk area, the structure is watertight
and able to withstand hydrostatic pressures from a water level equal to the
elevation defining the flood risk areas." (R 281.24 (10)).

EVALUATION

1. Structural facilities proposed for properties wholly contained
within a designated flood hazard area must be able to comply with
flood-proofing requirements for protection of the site from risk to
life and property values.

2. Structural facilities proposed for properties partly within a
designated flood hazard area must either: a) be sited in areas
outside of the designated flood hazard area; or b) must provide
adequate flood-proofing design approved by the DNR or local
administering entity for DNR.

1-80

Coal stockpiling and non-structural coal handling equipment and
facilities are not restricted under the Great Lakes Shoreland
Protection and Management Act provisions pertaining to flood
hazards.

SPECIAL LANDS LEGISLATION

Natural Rivers Areas

The Natural River Act , Public Act 231 of 1970, . provides for
designation of "a river or portion thereof , as a natural river area for the
purposes of preserving and enhancing its values for water conservation, its
free flowing condition and its fish, wildlife, boating, scenic, aesthetic,
flood plain, ecological, historic and recreational values and uses.' ,1

There are at least three classes of potential river designation -
wilderness, wild-scenic and country-scenic - the purposes of each being to
provide appropriate protection for recreational, scenic, historic, cultural,
economic and environmental values. Designated rivers are free flowing and
tend not to be intensively developed. Generally speaking, land presently in
industrial use would not be included within Natural Rivers designation areas,
and, in addition, proposed industrial facilities within a designated natural
river area would ordinarily be found incompatible with the original purposes
of designation.

River areas presently designated and other potential natural river
areas under study are depicted in Figure 1-3. Note that coastal zone area
designated natural rivers presently include the Two Hearted, White, Betsie,
Pere Marquette, and Rifle Rivers.

Agriculture@ and Open Space Areas

Under the Farmland and Open Space Preservation Act, P.A. 116 of 1974
as amended, landowners are entitled to voluntarily enter into a development
rights agreement with the state. These agreements (including easement
agreements) are legally recorded and ensure that enrolled lands remain as
active farmland or open space areas for an agreed period of time. In insert
Michigans natural river system return for maintaining the open space uses of
the land, the-landowner. is entitled to specific tax benefits..

The significance of the Act is that it effectively serves to assist
eligible landowners in retaining the lands agricultural or other open sp ace
values. As with designated Natural Rivers areas, this aspect of the program
implies that development of industrial facilities is not compatible with
purposes at the enrollment of land under the Farmland and Open Space
Preservation Act.

1-82

FIGURE 1-3
MICHIGAN'S
NATURAL RIVER
SYSTEM

HOUGHTON

33'

23 SARAGA LU I
% 76 CHI EWA
ALGER 76 CHI
-A
2% 1 EWA
A&ROUME
%4 ir -F%.CI'O.LC.1.1
t GICKINSC_i@\ .:*_ - -I _%
.% F MACKINAC
T.
24%

Ik
I L too

1M.ET CHEBOYGAN

PRESQUE ISLE
CHARLEVOIX
AL11N-
A kA6;61CY 01
29
_jA@k_A-SK@ WIFORD1 OSCODA ALCONA
DESIGNATED NATURAL RIVERS BENZIE G 0 *j
RA RS *
3
1. Two Hearted 6. Boardman W I;i KISCO
MANIS WEX@M% ISSAUKEE.ROSCOMMO -
2. Jordan 7. Huron I ,
3. Betsie 8. Pere Marquette *r 9
4. Rogue 4@ *'.
!: ' + $s I fLARE GLADw#N ARENAC
9. Rifle MA &N.L - LAII. 1
5. White % * I I HURON
15 %,.,. r
----RIVERS PROPOSED FOR STUDY /@17
SAY
EWAYGO ME(JOSTA ISABELLA -ii-iOLAND
10. Indian 23. Ontonagon @TUSCOLA I SANILTAC.
11. Fence 24. Paint
5
12. Fox 25. Huron
M_&N_T6ALM 'FGikrIOT SAGINAW
13. Black 26. Escanaba 3t---
14. Pigeon 27. Flat
- - 3 LAPEE'" .
7
KENT %36 -
EE
15. Little Manistee 28. Tahquamenon _ . I,
4 ST. CLAIR
SSii.
16. Whitefish 29. Thunderbay @;TTAWA IONIA VCLINTON ISM'AA
27 2d
17. Muskegon 30. Fish Creek OAKLAND
18. Thornapple 31. Cass 62 IMACOM"!
7W.@A;j@ 4.10M
19. Kalamazoo 32. Grand _;L-LF.C@A_N_ eiftiY EAT@@
20. Shiawassee %@- -1 1. 1 1 i
33. Sturgeon
21. Paw Paw 34. Dowagiac
22. Presque Isle 35. St. Joseph % CA ILHOt WAYNE
N GUREN KAbkMAZCID'
A ;N 'WAS 'NAW
!I%_@ 4,
RIVERS UNDER STUDY:
ST. JOS-7-' __jW_A@NC5H@_' ";jE LENAWES MONROE
National Wild-Scenic River Program
36. AuSable 37. Manistee & Pine 34
I J1 35
k-7-74-

NOTE: All rivers include some tributaries.

1-83

ZONING AND OTHER LOCAL ORDINANCES

Although the legal history of zoning law in America is a complex and
rapidly evolving area of public policy, the following section will endeavor to
describe the major statutory provisions enacted by the legislature which
specify the purposes and intent of local government zoning. other local
ordinances-often collectively cited as "nuisance laws" or "police powers of
local government" - must generally prescribe to the same kinds of tests for
reasonableness of regulation. Local ordinances of this type include laws on
air and water pollution and restrictions on routing of trucks. The following,
specific to local zoning ordinances, also generally describes the limits of
local regulations under this more general range of local government activities.

The state enabling legislation for local zoning dates back to 1921,
when Public Act 207 the City and Village Zoning Act was first adopted. That
original Act has been amended several times, most recently by Public Act 638
of 1978. Similar legislation has been adopted which enables the enactment of
zoning ordinances by townships (Public Act 184 of 1943) and counties (Public
Act 183 of 1943). All of the initial enabling legislation have been recently
amended.

Collectively, these Acts provide that the legislative body of cities,
villages, townships and counties may regulate and restrict the use of land and
structures by dividing a geographic area into districts. Under* each of these
Acts, local zoning in Michigan is voluntary and not compulsory. According to
the enabling legislation, established zoning districts may permit, exclude
from some districts, or subject to special regulations, all land uses.

However, the ability of a city, village or other local entity to
exercise its zoning authorities is not completely unfettered. Several
conditions for determining whether an adopted ordinance is a valid regulation
can be specifically cited from the state enabling legislation and as a
consequence of state court interpretations of zoning ordinance. These general
limitations on the authority of local government to enact land use
restrictions under zoning ordinances include:

1. Regulations and districts authorized by the zoning enabling
legislation must be in accordance with a plan designed to promote and
accomplish objectives of the enabling legislation (Public Act 638, of
1978);

one of the major differences between enabling legislation for
incorporated jurisdictions, township, and county zoning, concerns
intergovernmental review.
Incorporated cities and villages are autonomous, and formal review and
coordination proceedings by state and other jurisdictions is not required.
County zoning ordinances, require review and approval by the DNR, though
it has been proposed that this function be switched to the Department of
Commerce.
Township zoning requires that the county government be permitted an
advisory role, but county or state approvals are not required for zoning.
All local zoning regulations of wetlands, floodplains, coastal
environmental areas, and designated natural rivers, are subject to DNR review
and approval.
1-84

2. Although use of one's properties subject to ordinances designed to
promote common good, regulations and districts must bear some
meaningful relationship between restriction on property use and valid
exercise of power. (Deltowne Housing Corporations v. City of
Escanaba, 65 Mich App 624). Legitimate purposes recognized by the
state for zoning include: to meet the needs of the state's residents
for food, fiber, energy and other natural resources, plac-es of
residence, recreation, industry, trade, service, and other uses of
land; to insure that uses of the land shall be situated in
appropriate locations and relationships to limit the inappropriate
overcrowding of land and congestion of population and transportation
systems and other public facilities; to facilitate adequate and
efficient provision for transportation systems, sewage disposal,
water, energy, education, recreation, and other public service and
facility needs; and to promote public health, safety, an welfare.

3. A zoning ordinance may be found unreasonable (using the judicial
'larbitrary and capricious" standard) if the ordinance excludes
legitimate land uses where such land uses are permitted in another
district (Werkhoven v. City of Southfield, 75 Mich App 188 and
Deltowne Housing Corporation v. City of Escanaba, 65 Mich App 624).

4. Although property need not be zoned for its most lucrative use,
depreciation of land values may be considered as a factor in
determining whether a zoning classification is unconstitutional as a
taking without just compensation. (Equitable Bldg. Co. v. City of
Royal Oak, 65 Mich App 223).

EVALUATION

1. Zoning (or other locally adopted) ordinances are most likely to be ruled a
valid regulation if the ordinance has been adopted by the local
legislative body according to acceptable procedural steps and if the
regulation represents a reasoned approach to protection of public health,
safety and welfare.

2. A zoning ordinance may preclude uses which it finds incompatable to a
given geographic area if the use is an unlawful use, if no location exists
where the use can appropriately be cited, or if the local entity has
provided or set aside other areas specifically suited for accomodating the
proposed use.

3. With respect to coal transportation facilities and associated industrial
development, a local entity retains regulatory jurisdiction, if it
chooses, over siting deisions within certain statutory and judicial
limitations outlined in the main text.

4. Local entities also possess general powers to regulate nuisances to public
health, safety, and welfare. The scope of such powers does not extend to
regulation where the ordinance is determined to be "arbitrary and
capricious."

1-85

RECREATION PLANNING

The state of Michigan's recreation planning efforts date back to the
1965 adoption of Public Act 316. This act authorizes DNR to "prepare,
maintain and keep up-to-date a comprehensive plan for the development of the
outdoor recreation resources of the state." The most recent plan, approved in
1979 urges that i@ i@2a public responsibility to. "address inbalances in
recreation opportunity. The results of extensive inventory and analysis by
the DNR indicates that for several distinct reasons urban recreational
opportunities and facilities present the most serious policy issues, although
historically more emphasis was given to provision of recreation facilities in
rural areas, including northern Michigan. This conclusion is of special
significance to the study of coal transportation in that: a) loss of
recreational opportunities has been identified as one of the potential adverse
impacts of increased coal utilization; and b) it can be anticipated that much
of the future increase in coal use will occur in southern Michigan urban areas.

The following statements extracted frT the 1979 Recreation Plan
assist in identification of the geographic issues :

1. Michigan's densely populated southern regions have a smaller share of
the state's water resources on a per person basis compared to northern
regions ... Public programs have not sufficiently emphasized
developing to the fullest possible extent the recreation potential of
the limited physical resources in southern Michigan, particularly the
southern Michigan, Great Lakes shoreline.

2. Private lands are being closed to public use at an alarming rate,
resulting in more pressure on public resources particularly in
southern Michigan.

3. Rapid development of available open space will continue reducing
potential recreation sites, particularly in high population growth
areas ...

4. Valuable agricultural lands and wetlands continue to be lost to
competing uses ... One result of rapid and unguided development is
destruction of valuable plant communities and animal habitat, and the
recreation potential attached to them.

5. Regional and state (land use) controls are inadequate to assure the
future availability of these areas as potential recreation resources.
There is no long-range comprehensive or even shortrange development
plan to guide state and local development.

Compounding this perceived imbalance in recreational opportunities,
the state recognizes that financing fo
,@ operation of recreational facilities
is declining at local and state levels. Securing reliable sources of revenue
for site acquisition, capital improvements and operations financing is
therefore of continuing concern to recreation planners. The state has placed
emphasis on cost-effectiveness of programs, support for state and local
legislation providing fiscal support to meet rising costs and lost program
revenues, and encouragement of private recreation opportunities and facilities
where appropriate.

1-86

The state recreation plan addresses protection of the recreation
resource base, again emphasizing the adverse effects of rapid development of
available open space particularly in southeastern Michigan. Management
actions to correct the perceived loss of agricultural land, wetlands and other
open space areas suggest that state recreation planners place a high priority
on securing effective land use legislation.

Of assistance in the future, recreation planners and others will be
able to utilize results of resource inventories conducted pursuant to P.A. 204
of 1979. The Resource Inventory Act provides for funding and technical
assistance to be made to municipalities, counties and regional planning
commissions for participation irf a uniform inventory process.

EVALUATION

1. Recreation needs. State recreation planning has recognized that some of
the most severe imbalances between recreational needs and facilities are
to be found in southern Michigan urban regions. This imbalance has been
recognized as a I.egitimate state concern.

2. Need for matching facilities. Maintenance of urban waterfront park
facilities and development of future waterfront recreation facilities
within urban regions are key elements in the effort to efficiently serve
the recreation needs of large segments of the population.

3. Depletion of recreational resources base. Particularly in southeast
Michigan, it appears that overuse of recreation facilities, improper use
of facilities and land development in general continues to deplete the
natural resource base and environmental attributes necessary for
pleasurable recreation.

4. Use of underdeveloped waterfront areas. Vacant and usable urban
waterfront areas in southern Michigan (including southern Lake Michigan,
southern Lake Huron, Lake Erie, Lake St. Clair, and the Detroit and St.
Clair Rivers) have potentially high values for recreation facilities and,
in other instances, as undisturbed areas.

5. Conflicts between user along waterfront. Vacant, usable waterfront areas
within southern Michigan simultaneously may also represent necessary sites
for accommodating coal-based and other industrial development. Much of
the anticipated growth in coal use is anticipated to occur in the vicinity
of urban waterfront areas, particularly in southern Michigan. Hinterland
industrial coal use development in many instances will also requi.re
movement of coal through the southern Michigan urban shorelands area.

6. Need for land use planning. Land use planning of ports and other
waterfront areas, which @il-ght be able to assist in local and state efforts
to accommodate diverse recreational, industrial, commercial and other land
use requirements, are simply not adequate for the task at hand. The
likely future outcome is continued presumption of opportunities for public
access and other recreational activities by scattered residential,
industrial and commercial land developments.

I@87

7. Programs for acquiring national acres and potential park areas. Monies
for the acquisition of natural areas, for purchase of potential park
facilities, and for development and maintenance of recreation facilities
has become increasingly constrained. In the face of limited fiscal
resources, improved land use planning or cooperation with private
developers including compensation by developers for destruction or
impairment of public resources may represent the only remaining means for
effectively guaranteeing opportunities for public use of the waterfront
zone.

8. Public access. Insufficient attention appears to have been given by the
state recreation plan to possible alternative means of assuring public
waterfront access, particularly in conjunction with issuance of state
permits for private developments, including proposed coal handling
facilities.

1-88

RELATIONSHIP OF FEDERAL AND STATE COASTAL ZONE
MANAGEMENT PROGRAMS TO COAL TRANSPORTATION

Background on Michigan's Coastal Zone Management

Sections of the Coastal Zone Management Act, as amended, which ,are of
particular relevance to this study and to the Coastal Energy Impact Program in
general include:

� Subsection 305(b)(8) encouraging each state program to include a
planning process for energy facilities-,

� Subsection 308(d)(1) and (2) providing credit assistance to help meet
state and local needs to finance most of the new public facilities
and public services that are required as a result of coastal energy
activity.

� Subsection 308(c)(1) making grants available to states to study and
plan for any economic, social, or environmental effects of energy
facilities of all types in or significantly affecting the coastal
zone;

� Subsection 308(c)(3) making grants available to states to mitigate or
ameliorate environmental and recreational impacts arising from the
transportation, transfer and storage of coal.

States (or local entities through the state) are eligible under the
coastal energy impact program for grants to be used for "preventing, reducing
or ameliorating unavoidable losses of valuable coastal environmental or
recreational resources when such losses result from coastal energy facility"
and to "ensure that the person or persons respo s le for these environmental
or recreational losses pay for their full cost."T ' ip

The present study provides much of the information necessary for
assisting the state in planning for economic, social and environmental
consequences of coal transportation. To fully evaluate coal related energy
facilities, an analysis of use of coal by industries and utilities should be
undertaken.

Federal Consistency with the Michigan Coastal Zone Management Program

The Federal Coastal Zone Management Act requires federal agency
coastal zone actions (including development projects and activities requiring
federal licenses or permits) to be consistent to the maxirym extent
practicable with the approved state coast-al zone management program.

The Department of Natural Resources, Division of Land Resource
Programs has been designated as the state agency responsible for federal
consistency requirements. Substantive requirements of programs administered
by the division for "controlling soil erosion and sedimentation, natural
rivers, inland lakes and streams, natural areas, Great Lakes submerged lands,
shoreland erosion and flooding, and coastal wetlands protection" are to be

1-89

utilized by the Land Resource Programs in consistency review. Air and water
quality permit reviews by DNR divisions along with other state and local
agencies, in addition, are to be "coordinated for coastal consistency 5by the
Coastal Management Program Unit" of the Land Resource Programs Division.

More detailed information on procedural and substantive aspects of
Michigan's coastal management program are discussed below.

Energy Facility Siting and the Michigan Coastal Zone Management Program

The State of Michigan has no legislation directly governing the
siting of energy facilities. However, the state utilizes its 'comprehensive
permitging system' to review proposed energy facility siting projects in the
state, and exerts a great deal of authority over facility development through
the implementation of various environmental statutes. The state influences
the siting of energy facilities by insuring that the project is in compliance
with the associated environmental protection policies including incorporation
of specific terms ayd conditions into the permit to mitigate advance
environmental effects.

Several permits from the Department of Natural Resources are required
before construction of an energy facility can be initiated. These are
summarized as follows.

MAJOR STATE ENVIRONMENTAL PERMITS REQUIRED

TO CONSTRUCT AN ENERGY FACILITY

Requirement Authority

National Pollutant Discharge Elimination (NPDES) Act 245 of P.A. 1929,
permits for all point source discharges to as amended
surface waters

Permit for all discharges to groundwater Act 245 of P.A. 1929,
as amended

Soil erosion and sedimentation control permit Act 347 of P.A. 1972

Permit to erect a structure in or alter the flow Act 247 of P.A. 1955
of navigable waters of the Great Lakes

Permit to physically alter inland lakes and streams Act 346 of P.A. 1972

Permit to install source of air emissions Act 349 of P.A. 1965,
as amended

Permit to dispose solid wastes Act 641 of P.A. 1978

Source: Adapted from State of Michigan Coastal Management Planning Processes,
September, 1978, page 14.

1-90

As previously indicated that DNR's Division of Land Resource Programs
is responsible for administration of many of the major environmental statutes.
The Land Resource Programs Division is also charged with determining federal
consistency in cases where determination of consistency with the state coastal
zone management program is necessary.

Another division of the DNR which has major responsibilities for
coordination of DNR permits is the Environmental Enforcement Division. The
Environmental Enforcement Division coordinates the issuance of DNR permits
(when multiple permits are required) for all facilities, including energy
developments. To streamline the review process, the Environmental Enforcement
Division encourages a preliminary meeting held between the applicant and
appropriate DNR divisions. At this meeting, it is intended that the applicant
and DNR will discuss primary and alternative sites, methodology for sSlection
of sites, and preliminary DNR recommendations for use by the applicant.

Evaluation of Michigan's Coastal Zone Management Program

Under the various authorities comprising the Michigan Coastal Zone
Management Program, the state appears to be making good progress in dealing
with many identified coastal concerns including protection of critical fish
and wildlife habitat, conservation of shoreline dune areas from indiscriminate
mining, accommodation of industrial and commercial water dependent uses,
acquisition of critical environmental areas, and protection of life and
property against hazards. This is particularly true becasue of the networking
of many programs through Michigan's coastal management program.

In order to continue the progress of coastal management, the state
may wish to consider the following items. These suggestions are provided as a
means of increasing the utility of the state coastal zone management programs:

1. The Great Lakes Basin Commission, based on review of published state
documents and conversations with state officials, suggests that
additional long-range planning for the following coastal activities
would be helpful in the following areas:

(a) dredge and dredge disposal needs and siting;
(b) additional coastal port development and planning (such as
completed for St. Joseph/Benton Harbor and the Saginaw River) in
order to provide means for protecting envi@ronmental values and to
assure that adequate areas are maintained for accommodating
water-dependgnt industrial and commercial development (port
inventories are currently being conducted by Michigan Department
of Transportation);
(c) energy facility siting which assures adequate planning and
accommodation of new facilities consistent with national interests.
(d) assuring public access particularly in the southern Michigan area
where the state recreation plan has identified severe, recreational
demand/supply imbalances.

2. Completion of shoreline maps as coastal resource inventories including
the coastal zone boundary areas, land uses, environmental values, and
identified geologic hazards would help state and local planners as
well as private developers. Two-thirds of the Michigan shoreline has
already been mapped.
1-91

3. Tables 1-7 and 1-8 provide a comparative compilation of state programs
for coastal resources prepared by National Oceanic and Atmospheric
Administrat ion. This compilation may suggest future policy areas for
state consideration.

1-92

TABLE 1-7

Summary of State Protection of Historic and
Cultural Resources under CZMA

State Required Open Protec. Protec- Urban
Dedication Beach tionlRes. tion of Waterfront
of Access Laws or toration of Scenic Projects
Court Historic Areas/
Action and Prov!sion
Cultural Of Visual
Resources Access

Alabama P P P
Alaska X X
California X X X
Connecticut New Haven,
X Stamford,
Norwalk
Delaware X Wilmington,
Newcastle
County
Florida Miami. Sarasota
Georgia X P Brunswick,
St. M a ry's
Guam X X
Hawaii X X X X Honolulu
Illinois X X Chicago-
Waukegan
Indiana
Louisiana Moon Walk,
X Lincoln Park
Maine Calais
X South Portland,
Vinalhaven
Maryland X X Cambridge Creek
Massachusetts X X
Michigan X X Detroit
Minnesota Duluth
Mississippi Gulfport
New Hampshire P P Portsmouth,
P P Exeter
New Jersey X X Jersey City
New York P X Buffalo
North Carolina X Wilmington
N. Marianas
Ohio
Oregon X X X
Pennsylvania P P
Puerto Rico X X San Juan
Rhode Island X X
(Am.) Samoa
South Carolina X X
Texas X
Virgin Islands X X X X
Virginia Alexandria,
Norfolk, New-
port News, and
Virginia Beach
Washington X X Seattle
Wisconsin X X Milwaukee,
Kenosha

X-Pre-existing law or program incorporated into CMP or new or expanded law or
program directly attributable to CZM participation.
P-Propose@ law or program,to be part of Coastal Management Program.
Source: National Oceanicand Atmospheric Administration, Office of Coastal Zone
Management, "The First Five Years of Coastal Zone Management," (Washington,
D.C., U.S. Department of Commerce, March 1979) Table V, p. 39.

1-93

TABLE 1-8

Summary of State Laws Affecting Management of Coastal Development
(by type of activity or area affected)

State Erosion-Prone Floodplains Subsidence Energy Pritor Locating Offshore
r% to
Areas and/or Facility Wa ,P. Dredge Oil & Gas;
L
Saltwater Siting Uses D 1 1 Sand & Gravel
Intrusion Extraction

Alabama P P X X
Alaska X X X X X X
California X X X X X
Connecticut p X
Delaware X X
Florida X X
Georgia X X X X
Guam X X
Hawaii X X X X X
Illinois X X X
Indiana X X X
Louisiana P P P X F, p
F-q Maine X X X X
I Maryland X X X
10
Massachusetts X X X X X X
Michigan X X X X
Minnesota X X X
Mississippi P P
New Hampshire X P F, P
New Jersey X X X
New York P P X P X X
North Carolina X X X P X P
N. Marianas
Ohio P F, X X X
Oregon X X X P X
Pennsylvania X X P X
Puerto Rico X X X
Rhode Island X X X X
(Am.) Samoa
South Carolina X X X
Texas X X P P
Virgin Islands X X X X X
Virginia
Washington X X X X X X
Wisconsin X X X X X X

X = Pre-existing law or program incorporated into CMP or new or expanded law or program directly attributable to CZM Participation.
P = Proposed law or program to be part of CMP.
Source: National Oceanic and Atmospheric Administration, Office of Coastal Zone Management, "The First Five Years of Coastal Zone Management," (Wash-
ington, D.C., U.S. Department of Commerce, March 1979) Table IV, p. 31.

FOOTNOTES

P.L. 94-370, Section 308(b) and 308(d)(4) as discussed in implementing
regulations CFR Volume 15, Sec. 931,71 1979 edition, page 822.
2 The CEIP (Coastal Energy Impact Program of the Coastal Zone Management Act)
"will be administered in a manner that will strike a balance between
the major national goals of obtaining a greater degree to energy
self-sufficiency and protecting the coastal environment:

(1) Only coastal energy activities for the rational, timely and
orderly development of the Nation's coastal energy resources will
be encouraged; and

(2) Unnecessary development in the coastal zone will be discouraged
by providing financial assistance or only for those public
facilities and public services that are actually needed because
of coastal energy activity.
3 Although federal activities and projects within the coastal zone require
consistency review, it should be clarified that, by definition,
federally-owned land s--irrespec t ive of location--are not considered
part of the coastal zone area. Federal activities on federal lands,
however, may require consistency determination if the activity
significantly affects non-federal coastal zone land areas. In
addition federal activities outside the coastal zone (for example,
landowned of the coastal zone) are subject to consistency review to
determine whether the activity significantly affects the coastal zone.
4 State of Michigan Coastal Management Program and Final Environmental Impact
Statement, U.S. National Oceanic & Atmospheric Administration, July
1978, page 146.
5 ibid
6 State of Michigan Coastal Management Planning Processes: Energy Facility
Siting, Shorefront Access, Shoreland Erosion, Michigan DNR, Division
of Land Resources Programs, September 1978, page 10.
7 ibid, page 10
8 ibid, page 11

1-95

PORT DEVELOPMENT IN MICHIGAN

Current Situation

Port development and planning in Michigan is determined by the
structural divisions between the state and local political bodies and the
relationship maintained among these groups. The Michigan Department of
Transportation has a planning responsibility for port development and is
currently conducting a state-wide port needs study which will evolve into a
state port plan. The study is being conducted with the cooperation of local
political interests. The purpose of the study is to identify opportunities
for commercial harbor development and to quantify funding requirements for
implementation. In addition, the Coastal Zone Management Program of the
Michigan Department of Natural Resources has funded and will continue to
support special studies of specific commercial harbors to identify management
options related to potential project development.

For purposes of discussion, it is useful to group coal receiving
ports in the state of Michigan into three categories (see Table 1-8). The
first group is the largest, containing 17 commercial harbors that have no
local port management organization and rely on the state or local planners for
any planning required.

The second group, containing four harbors, has local harbor
commissions established by ordinance that are part of the governmental unit or
units which created them. These commissions meet occasionally to deal with
specific problems and generally have a local planning agency provide the only
staff member.

The third, and smallest group with two members, has port authorities
with both management and planning responsibilities. The Port of Monroe
operates under the provisions of Act 234 of 1925, as amended, and the Port of
Detroit was recently reorganized under the provisions of Act 639 of the Public
Acts of 1978. (The Port of Detroit operated under Act 234 of 1925 from 1932
to 1980). Both authorities are semi-independent with jurisdiction extending to
the political limits of the city or county that created the authority.
(Detroit-Wayne County and City of Monroe-Monroe). Monroe is a good example of
a Michigan port which is well planned and is expanding its facilities at a
rate which is keeping up with the demands for waterborne commerce, including
coal.

Current Policy

Act 639 of the Public Acts of 1978 offers a new approach to local
governments in the management of their water resource. A city and county, two
or more counties, or any combination including at least one county and one
city may, by joint resolution, request the Governor for authority to
incorporate a Port Authority. Upon approval by the Governor, the Authority is
eligible for Department of Transportation assistance for 50% of the annual
operating budget and for capital grants for specific projects. The Governor's
appointment of one member of the Port Authority Board ensures the active
participation of state agencies in furthering the objectives and program of
the Authority.

1-96

The establishment of a local Port Authority under the provisions of
Act 639 of the Public Acts of 1978 requires the approval of the Michigan
Department of Transportation and Department of Commerce prior to approval of
the Governor. The Departments of Transportation and Commerce must also
approve the Port Authority annual program, budget and the comprehensive port
plan required by the Act . (Act 639 of 1978 provides that Act 234 of 1925, as
amended, is repealed when both Detroit and Monroe organize under Act 639.)

Although Act 39 offers the benefits of state oversight and approval
of port development and state financial -assistance to local authorities, it
does not provide for state initiation of port development projects. Local
initiative must be present both in the establishment of an authority and in
the request for state financial assistance. The final work concerning when
and where port development occurs in Michigan, therefore, within local
government jurisdiction.

Evaluation

The inability of the state under current law to undertake port
development projects independently of local authorities has yielded arguments
in favor of a statewide port authority. Those supporting such an agency argue
that greater state control of port development would produce greater
coordination, and perhaps as a result ' more efficient use of Michigan's port
facilities. Some proponents of a statewide authority contend that the current
lack of development in many potentially valuable Michigan ports may put
Michigan at a disadvantage with respect to its ability to handle newer
transportation technologies, and consequently, at a competitive disadvantage
in terms of ability to attract new industry and the jobs that come with it.

Among the arguments posed by those favoring the current system of
local port authority emphasis is the assertion that the creation of a
statewide authority could lead to a inefficient allocation of resources due to
what could be expected to be a glut of demands for state funds. In other
words, this point of view would contend that where only those ports with the
best potential are encouraged to establish port authorities, state funds, in
the form of aid to these ports, would only be spent in the most promising
areas. Establishing a state authority, on the other hand, would entitle many
state ports to some aid, including those whose further developmet may not be
in the public interest, and could create a budgetary disaster.

It seems that perhaps a middle ground between the two would be
preferable to either. A state port authority which possessed both the power
to initiate port planning and development projects, yet at the same time
retained the authority to deny funds to ports where development may not be in
the public interest, may be ideal. Perhaps it would be worth while to study
the operation of state port authorities in states such as Georgia, Indiana,
Massachusetts, Mississippi, the Carolinas, and others, in an attempt to learn
what works in these states and how it could be applied to Michigan. The fact
is, that whatever path is taken, greater port planning and development is
clearly needed in Michigan. A continued lack of port development progress on
a large scale may have an adverse effect on the ability of the state to
compete with other coastal states for commerce, and to receive waterborne
shipments of commodities such as coal.

1-97

TABLE 1-8

MICHIGAN COMMERCIAL HARBORS RECEIVING COAL BY_WATER

A. Ports with no comprehensive management or planning functions:

� Muskegon Harbor * Menominee Harbor
� Charlevoix Harbor e Petoskey Harbor
� Harbor Beach o Gladstone Harbor
� Mackinac Harbor o Holland Harbor
� Marquette Harbor * Alpena Harbor
� Traverse City Harbor 9 Presque Isle Harbor
� Frankfort Harbor e Ontonagon Harbor
� Saginaw River e Calcite Harbor
� Escanaba

B. Michigan Parts with Harbor Commissions established by ordinance:

� Grand Have Harbor o Ludington Harbor
� Manistee Harbor o St. Joseph Harbor

C. Michigan Ports with Port Authorities

o Port of Detroit
e Port of Monroe

1-98

ORGANIZATION OF MICHIGAN DNR

Introduction

The state presently has no legislation directly governing the siting
of energy facilities. Coal transport infrastructural proposals, for example,
are regulated only to the extent which the proposed facility involves
application of other statutory authorities, including the various state
environmental protection and resource management programs.

A number of statutes do exert some influence over the siting of coal
transport facilities by virtue of the project impact on specific geographical
areas or state concerns. For example, the Great Lakes Submerged Lands Act,
Inland Lakes and Streams and the Wetlands Protection Act effectively assure
that physical alterations and structural improvements within most of the
state's waters will be subject to permit authorities. Likewise, the state's
Soil Erosion and Sedimentation Act requires a permit prior to clearing and
grading projects of more than one acre in size (or if within 500 feet of a
water course). Along the coastal zone, the Shorelands Management and
Protection Act applies to sites which have been designated by the state either
for f lood and erosion protection or because of exceptional environmental
values. The Air Pollution Control Act, in addition, applies to installation,
construction, reconstruction or alteration of any process or system which may
be a source of air contamination, including coal transshipment and stockpiling.

These and other pertinent state legislation are discussed in this
report. These statutes often empowers the states Department of Natural
Resources (DNR) with permitting authority over new coal transport facility
proposals. Frequently, however, administrative attention is logically
extended only to those components of the proposed operation which are
pertinent to the resource being administered as specified by the relevant
legislation (e.g. the Erosion and Sedimentation Control applies to erosion
effects of earth moving and not to other possibly significant economic or
environmental aspects of the proposal).

The lead state agency for administering environmental legislation
within Michigan is the Department of Natural Resources. Act No. 17 of the
Public Acts of 1921 established the Department with duties to "... protect and
conserve the natural resources of the state of Michigan; provide and develop
facilities for outdoor recreation ... prevent and guard against the pollution
of lakes and streams within the state, and enforce all laws provided for that
purpose

Six DNR commissions are responsible for a wide range of policy
issues:4

o Natural Resources Commission (established by Act No. 17 of the Public
Acts of 1921), is comprised of seven citizen members appointed by the
Governor and serves as the Department of Natural Resource's board of
directors. In the Commission rests responsibility for setting policy
which guides the Department programs. As noted previously, the
Commission appoints the Director of the Department.

1-99

� The Water Resources Commission (established by Act No. 245 of the
Public Acts of 1929), is composed of four ex-officio directors of state
agencies, including the Department of Natural Resources, and three
appointed citizens. The Commission is charged with responsibility to
protect and conserve water resources of the state; control pollution
over waters of the state; and prohibit pollution of waters held in
public trust. These objectives are accomplished largely through
permits, surveillance and enforcement. The Commission is also directed
to develop adequate wastewater collection and treatment systems.

� The Air Pollution Control Commission (established by Act No. 348 of the
Pubilc Acts of 1965), contains 11 members; three ex-officio directors
of state agencies, including the Department of Natural Resources, and
eight appointed citizens. The Commission's major role is to prevent
new sources of air pollution and to reduce air pollution from existing
sources through compliance with air quality.

� The Resource Recovery Commission (established by Act No. 366 of the
Public Acts of 1974), is composed of the directors of the Department of
Natural Resources and Treasury Department, and nine appointed citizens.
The Commission is responsible for managing disposal of refuse.

� The State Waterways Commission (established by Act No. 320 of the
Public Acts of 1974), is composed of five citizen members. Its primary
function is to acquire, construct and maintain harbors, channels,
pubilc access sites and facilities for recreational boating.

� The Mackinac Island State Park Commission (established by Act No. 355
of the Public Acts of 1927), has seven citizen members which are
appointed by the Governor. Its objectives are to provide for public
use and historic preservation of Mackinac Island State.

There are 27, DNR divisions and offices, which serve the state. The
relevant divisions and offices are listed and described in alphabetical order.
Information presented is from DNR's forthcoming publication "Working For You".

Air Quality

The goal of the Air Quality Division is to achieve and maintain a
level of air quality consistent with national standards for protecting the
health and welfare of the pubilc. The Division is directly responsible to the
Michigan Air Pollution Control Commission for all actions taken to fulfill
that obligation.

Achievement of the goal demands comprehensive review of all proposed
new potential sources of emissions; strict, continuous investigation and
surveillance of all operating sources, and constant monitoring of current
pollution levels. To insure that each activity is properly carried on, four
sections, each responsible for specific phases of Division programs, have been
established:

The Engineering Section is responsible for permit application
processing, plan review, tax exemption review, environmental impact analysis,
emission inventory, and surveillance fee assessment.

I-100

The Compliance Branch inspects all sources of air pollution to
determine compliance with federal and state emission limitations, investigates
citizen complaints of air pollution problems, issues abatement orders, and
develops compliance schedules for facilities exceeding emissions limits.

The Technical Services Section is responsible for air quality sample
collection and data collation, analysis and interpretation of sampling
results, and collection of samples from specific source emissions.

Engineering

In addition to providing services to other Divisions of the
Department for project developments, the Engineering Division performs
topographic and boundary surveys, relocates survey corners, determines the
ordinary high water mark for Great Lakes fill and dredge activities, and
provides testimony and reports relating to those for the Attornty General,
Water Resources Commission, and the Department.

The Division reviews local government plans for federal and state
recreation bond projects and also approves their construction. It coordinates
Department review of engineering plans for county and state bridge and road
projects, submitted by the Department of Transportation, to assess effects on
the environment. The Division also participates in making damage survey
estimates, reports, and final inspections relating to federally declared
disasters.

Environmental Enforcement

Establishment of the Environmental Enforcement Division (EED)
relieves other Divisions of litigation responsibilities so they can pursue
other management programs. At the same time it provides a single contact
point for the Attorney General, thus streamlining the litigation process.

Criminal actions under environmental laws also are handled by EED.
Violations are investigated, coordinated and referred either to local
prosecuting attorneys or to the Attorney General. This function provides
reforcement posture to discourage violations which can have profound adverse
effects on public health and natural resources, and reduces the work load of
the law enforcement officers in the field.

The Division's second major function is environmental review. By
Governor's Executive Order 1974-4 all- state agencies are required to review
their actions to determine the necessity of Environmental Impact Statements.
This Division is charged with coordinating review of Environmental Impact
Statements prepared by the Divisions and approves them. The EED also serves
as the Department's clearinghouse for Environmental Impact Statements drafted
by other state agencies and federal units, which are submitted to the DNR for
review and comment. Department representation on the two environmental review
groups established by Executive Order 1974-4 is provided by staff of EED.

I-101

Environmental Services

The Environmental Services Division provides technical support
services to the Air Quality, Water Quality and Resources Recovery divisions,
and to the Department as a whole.

The Department's environmental laboratory is quartered within the
Division. The lab provides a full range of analytical services'to support the
Department's pollution control activities.

The Comprehensive Studies Section of the Division is responsible for
collecting data concerning the physical and chemical quality of Michigan's
rivers. This Section also develops waste load allocations and effluent
limitations for municipal and industrial facilities which discharge wastewater
into the surface waters of the state.

Lands

This Division is the "real estate" office and record center for the
4.3 million acres of state-owned land, 130,000 platted lots and 2.2 million
acres of mineral titles. Its records include an abstract of the initial
deedings under which 16 million acres of lands granted to the state by the
U.S. Government passed into private ownership. Original field notes of the
U.S. Land Office Survey for the entire state are also maintained in its files.

Besides keeping records and providing services for divisions of the
Department, the Lands Division helps shape policy and program decisions
involving land use for state owned lands.

As part of its major role in Department land affairs, the Division
since 1921 has sold or traded approximately 200,000 platted lots and more than
3 million acres of tax-reverted lands not suited for conservation purposes.
Under this phase of its operation, the Division schedules pubilc auction sales
of tax-reverted properties each year.

The Lands Division has a key role in the Department's long-range
development program, including acquisition of lands suited for recreation and
other environmentally sensitive areas. These purchases have provided new and
improved state parks, wildlife areas, water access sites, forest areas and
campgrounds, sites for administrative purposes, and other facilities related
to outdoor recreation and resource management. Purchases and gifts negotiated
by the Division have brought more than one million acres of land into public
ownership and use. The Department's land exchange program serves to
consolidate and bring into public ownership key areas better suited to meet
land management objectives.

Land Resource Programs

The Division of Land Resource Programs was established to consolidate
major land and related water resource management and planning elements within
one Division.

1-102

The Division works with local governments , private citizens and
organizations to achieve wise resource management through the various programs
assigned to it . Technical assistance and information are provided by the
Division to insure appropriate use of land and water resources for the
protection of Michigan's natural resources in conjunction with economic,
environmental and social needs.

Approximately 25 planning and environmental protection management
programs, which were enacted into law by the Michigan Legislature and the U.S.
Congress, are administered by the staff of the Division. These programs range
in scope from: local assistance, such as zoning and planning; financial
assistance, such as the Coastal Zone Management Program; land preservation,
such as the Farmland and Open Space Preservation Program; landowner
assistance, such as the Self-Help Water Quality Monitoring Program for inland
lakes. Regulatory programs such as the Soil Erosion and Sedimentation Control
Act and the state's Submerged Lands and Wetlands Acts are also administered by
the Division of Land Resource Programs.

Recreation Services

The Legislature created Recreation Services Division to provide
technical assistance to all recreation interest groups and agencies in the
state, to prepare and keep up-to-date a State Recreation Plan, and to
coordinate role all trail activities. These responsibilities fit together and
complement each other. Recreation and resource specialists, landscape
architects and community planners in the Division bring their professional
know-how to bear on state and community recreation problems.

The job of fitting all the resources and programs into one "big
picture" is reflected in the Michigan Recreation Plan. The Plan evaluates
resources, population projections, travel patterns, and changing social and
economic influences in light of findings from the public partici-pation
process. The Plan also charts possible courses to meet recreation needs and
projects.

Water Management

The Water Management Division promotes orderly development of these
waters and allied lands to meet commercial and industrial needs.

Various sections deal with flood plain management, hydraulic review,
dam construction, dam safety regulation, water use and hydrologic engineering.
General hydrologic studies conducted by the Division's staff are essential in
developing basic knowledge of the quantities and variations of Michigan's
water resources . The information is used to support departmental programs and
is provided to local units of government, other state agencies, and private
developers.

Water Quality

Primary responsibility of the Water Quality Division is to protect
state water resources and secure compliance with quality standards. The

1-103

Division consists of two branches-Pollution Control and Municipal Facilities
and Planning, and a Biology Section.

In the Pollution Control Branch are several sections, including The
Engineering and Technical Service Section functions primarily as a permit
development unit . Discharges of wastewaters to the ground or surface waters
of the state are allowed only by permits issued from the Water Resources
Commission. The permits contain limitations , restrictions and other
requirements to assure the protection of the receiving waters' quality.

The Oil and Hazardous Materials Control Section responds to
transportation-related spills throughout the state on a 24-hour basis. The
section also regulates licensing of liquid industrial waste haulers and septic
waste haulers, and conducts investigations and surveillance of those and other
pollution-related activities.

The Groundwater Compliance and Special Studies Section monitors
compliance with permit conditions for groundwater discharges.
Responsibilities include initiation of enforcement action against violators,
investigations of groundwater' contamination, and coordinating reviews of
hydrogeologic study proposals and reports. In addition, the section is
responsible for development and carrying out of groundwater studies and
projects.

The NPDES Compliance Section administers compliance with National
Pollutant Discharge Elimination System permits for surface water discharges.
Responsibilities include initiation of enforcement activities and follow-up
for violators, coordination with the Federal Environmental Protection Agency's
water pollution programs, and case preparation for referrals to the
Environmental Enforcement Division where litigation may result.

The Biology Section functions as the Division's scientific wing,
conducting biological and chemical surveys of lakes and streams to determine
the impact of waste discharges and other activities. Biologists review
existing and proposed permits, projects and activities, seeking to minimize or
prevent degradation of the waters.

Waterways

The Waterways Division spearheads construction of recreational
boating facilities on waters throughout the State. These include refuge
harbors, docks, launching ramps, channels, anchorage areas, parking areas,
access roads and public restrooms.

Initially, the program of the Waterways Division called for
construction of habors-of-refuge authorized by Congress in 1945. Such harbors
were designed to provide shelter for recreational boaters at approximately
30-mile intervals along the Great Lakes shores. This concept has been
expanded to 15-mile interval harbors in high population areas.

The Division participates with the Federal Government in
coordination, design and construction of commercial harbors and channel
facilities, and is involved in mobilizing local participation required for the
these projects.
1-104

Construction of docking and launching facilities on the Great Lakes
is part of the Waterways Program. These facilities are generally constructed
under grants-in-aid agreements with local communities and thereafter operated
by the community. However, the Division also operates a few facilities.

The public water access site program of the Department is under the
jurisdiction of the Waterways Division. More than 900 sites come under the
Division's responsibility, and more than 600 have been developed and are in
active use as boat launching facilities.

Recent program additions include the river use rules and
access-to-public-waters programs. Under the river use rules program, the
Division is surveying current uses of various rivers to determine a desirable
mix of activities and regulations and/or policy decisions required to allow
such uses. The access to public waters program involves Department action to
prevent abandonment or loss of existing accesses such as streets and roads
running to the edges of lakes and streams.

FOOTNOTES
1 The preceeding paragraphs extracted from Working For You, a forthcoming
Michigan DNR public information manuscript currently being printed.

2 State of Michigan, Department of Natural Resources, State of Michigan
Coastal Management Program and Final Environmental Impact Statement, July
1978, page 105.

3 Working For_You

4 Sources: Working For You and Michigan CZM Program and Final EIS, page

108-9.

1-105

TABLE J-1

MATRIX OF MICHIGAN ENERGY POLICY

POLICIES STATE PLANS RESIDENTIAL APPLIANCES
-Provide an energy -Aim for reduction im state's Promotes energy audits These should be no false
CONSERVATION conservation grants program, overall energy use in thp -Elimination of the sale of labeling of energy
for schools, hospitals, local future decorative maps that use eficiency
governemtns, and public care -An act to provide for the natural gas or liquid propane -Cannot sell appliances with
building declaration of a state energy gas. continously burning pilot
-Promote building surveys emergency providing for -Elimination of the sale of lights, except for water
-Conduct mini and maxi specific energy measuress appliances with continously heating or appliances using
audits -The Governor may declare an burning pilot lights except liquified gas.
-Promote and conduct energy energy emergency for ones using liquified gas Appliances shall be required
conservation projects or on hot water heaters to be labeled as to energy
-Restrictions may be placed on -Encouragement of residential use and efficiency
interior temperatures of audits
public, commercial, -Establishment of home
industrial and school -watherizaiton program for
buildings low income households
-Allowance of a state income
tax creit for hearing fuel
costs

TRANSPORTATION EDUCATION ELECTRICITY ENVIRONMENTAL

-Imposition of a motor fuel Develop centcus for public -Prohibit declining block -Restrictions may be imposed
tax information and education rates across the board on the use and sale of energy
-55 mile per houw speed -Development of Michigan -Restrictions may be placed on resources
limit Energy Information Systsms lighting levels and display -Mandatory deposit on bottles
-Right turn on red allowed -Promote energy education and decorative lighting and cans
-In emergencies restrictions within the school under the
on the use of privately owned Energy Extension Services
vehicles and reduced speed program
limits may be enforced

INDUSTRY/COMMERCIAL
Develop a program of
comprehensive energy audits
and conservation efforts

MATRIX OF MICHIGAN ENERGY POLICY (Con't)

WOOD SOLAR HYDROPOWER WIND

RENEWABLE ENERGY -Develop the wood energy -Provides for a state tax -Provision for a state tax -Provides for a state tax
program to promote wood for single and multi family credits for housing and rental credit for housing and rental
resources as an energy housing buildings that are owned by a buildings owned by a
sources -Provide technical solar taxpayers taxpayers
asistance educate the
public, and accelerte the
implemetation of solar
energy technology
-Provides for sales and use
tax exemptations for solar
equipment
Property tax exemption for
solar installations
USE

NATURAL GAS
-Man the sale of decorative
lamps which use either
natural gas or liquid propane
as its source of fuel

CONSERVATION

OIL
-Development of energy
conservation projects for
scientist, hospitals, local
governments, and public care
buildings

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4

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U.S. Department of the Interior, Bureau of Mines, Coal Transportation
Practices and Equipment Requirements to 1985, 197;_.

U.S. Department of Transportation and Department of Energy, National Energy
Transportation Study, July 1980.

U.S. Department of Transportation, Office of the Secretary, Rail
Transportation Requirements for Coal Movement in 1985, December 1978.

U.S. Department of Transportation, St . Lawrence Seaway Development
a
Corporation, Traffic Report for the 1978 Navigation Season, 1979.

U.S. Environmental Protection Agency, Industrial Boiler Technologies to the
Year 2000, 1980.

U.S. General Accounting Office, Dredging America's Waterways and Harbors -
More Information Needed in Environmental and Economic Issues .
CED-77-74, U.S. Government Printing Office, June 28, 1977.

U.S. House of Representatives, Committee on Interior and Insular Affairs,
United States Coal Production and Utilization, USGPO, Washington,
D.C., 1979.

U.S. House of Representatives, Committee on Interior and Insular Affairs
Constraints on Coal Development, USGPO, Washington, D.C., 1977.

U.S. Office of Technology Assessment, U.S. Congress, Direct Use of Coal
Prospects and Problems of Production Combustion, U.S. Government
Printing Office, 1979.

U.S. Senate, Committee on Energy and National Resources, Synthetic Fuels from
Coal: Status and Outlook of Coal Gasification and Liquifaction,
Publication No. 96-17, USGPO, Washington, D.C., June 1979.

U.S. Senate, Committees on Interior and Insular Affairs and Public Works,
Great Coal Utilitization, USGPO, Washington, D.C., 1975.

Valentine - Thomas and Associates, Inc. A Study of Shoreline Conditions and
Erosion Processes at the Grand Trunk Site. prepared for the City of
Port Huron, 1979.

World Coal Study, Coal-Bridge to the Future, Ballinger Publishing Company,
Cambridge, Massachusetts, 1980.

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