Coal’s Four Externalized Export Burdens
Proposed Northwest coal export terminals increased scrutiny of open-top rail cars which allow coal discharge into proximal waterways. Although Burlington Northern Santa Fe (BNSF) railroad implemented dust binding proto- col, noticeable discharge remains. That discharge may violate the Clean Water Act (CWA). My internship with Puget Soundkeeper Alliance (PSA) included industry research, identifying coal discharge to US waters, and considering whether point and non-point discharges violate the CWA. PSA is litigating coal discharge pursuant to the CWA, prompting Congress and the Public consider environmental harms. I identified undervalued leases, inadequate tax practices, fallen coal, and unmitigated carbon emissions as avoided externalities.