Coal Train Noise: Are You “Significant”?

We are here!  We are here!

David’s blog about the “no action alternative” for the proposed Gateway Pacific Terminal – North America’s largest coal export terminal  -- made me think about how we measure environmental “impacts,” also known as environmental “effects.”   

An impact is an effect, an effect is an impact, and both words refer to costs that the project applicant will impose on others.

Here’s one thing to know about environmental impact statements:  No impact matters unless the “Lead Agency” (here, the Army Corps of Engineers) decides that the impact is “significant.” 

If an impact is “less than significant” – poof! For all intents and purposes, the impact goes away. No mitigation measures are required.  The agencies don’t have to worry about the impact.  Your elected representatives won’t worry about the impact.  Really, nobody ever has to think about that impact ever again.

Except the folks who have to live with the project's "effects."  They may think that impacts are significant, but if the Corps doesn't think so, it doesn't matter.  

And so, I wonder how the Army Corps of Engineers is going to measure noise impacts from coal trains.  I wonder what standard it is going to apply. I wonder what impacts it will call "significant" and which impacts it will call "suck it up, sucker."

The Corps isn’t ordinarily in the business of dealing with large-scale noise impacts from trains.  I can’t find anything in the Corps’ NEPA regulations, or in any Corps guidance documents, that sets standards for noise impacts or provides guidance about how noise impacts will be measured.   Maybe it's there and I just didn't find it.

As far as I can tell, though, the Corps will establish a standard of "significance" based on its view of what makes sense.  It will listen to agencies.  And maybe it will even listen to the people who will be most affected. 

 

Here are a few things that we know about trains and noise. ·        
  
We know that there are at least two kinds of noise:  wayside noise (engine and wheel noise) and train whistle noise.  

We know that the Federal Railroad Administration requires freight trains to blow their whistles at 96-110 decibels, measured 100 feet in front of the train and 15 feet above the rail, near intersections. That’s a straightforward measurement of sound at a point in time.

Except that it isn’t straightforward, because decibels are logarithmic. An increase in ten decibels is roughly equivalent to a doubling in noise.  So a noise that we hear as 110 dBA isn’t 10% higher than a 100-decibel noise.  It’s about twice as loud.  A 20-decibel gain is about four times as loud.  A 40-decibel gain is about 16 times as loud.

Unless you have a vacuum cleaner or dishwasher going, your living room at the moment is probably around 40 to 60 dBA.  So a train whistle at 100 feet would be at least 16 times as loud.  With distance, the sound level goes down, and walls and windows reduce it too, of course. 

We know that noise varies over time. Time variability is usually addressed by averaging sound over a period of time – often, 24 hours.   You may see the term “Ldn.”  

• Ldn measures the “cumulative noise exposure from all events over a full 24-hour period, with events occurring between 10 pm and 7 am increased by 10 dB to account for greater nighttime sensitivity to noise."  
• (For those who want to read along, and especially if you want to learn more about train noise, here is the Federal Railroad Administration’s web page on “Horn Noise Questions and Answers.” )

When you put all that together, what do you get?

Train horns are really loud.   They’re not the loudest sound in the world – jet aircraft at 500 feet are louder, and some military blasts are louder.  (The Army Corps had consultants test whether night time military exercises affect people’s sleep.  They do.  The offending sounds were 110-120 dBA.)  

But they’re loud.  Rock concert loud.  Rock concerts are sometimes given as an example of a 110 dBA sound.  I also saw “squeaky toy held close to ear.”  Ouch.  Vacuum cleaners, by contrast, are 60-85 dBA.

“Loud” can go away when you "average" noise over time.  What happens when you “average out” the noise level?   

For people who live a thousand feet away from a “suburban crossing with horns,” the Federal Railroad Administration suggests that the average noise (60 Ldn) is no worse than an “urban residential environment.”  

This raises a red flag:

What if the Corps decides to "average" noise when it is determining significance?  What if it decides that, say, 65 or 70 Ldn is its standard for significant impacts? This would not be unheard of.  In fact, based on precedent, it may be more likely than not.

This would mean that everybody who experiences an "average" noise level that’s significantly worse than conditions today -- five, ten, forty times louder -- but not above this "level of significance," would just have to grin and bear it.  Train whistles disrupt your sleep?  Too bad, you're not "significant."

If that’s the standard of significance, an awful lot of people will be sacrificing an awful lot of sleep for the coal trains.

Or, the Corps can set a lower standard.  It can set a standard for high decibel, noncontinuous noises -- train whistles --  especially when they disrupt sleep.

How can that happen?  If you demand it.  If you think that you are significant, tell the Corps to measure noise impacts as if you mattered.   

Your comments don't have to be technical.  Just tell the Corps that "averaging" the noise isn't enough.  If loud whistles already bother you, say so.  If your friends and neighbors join you, and folks all along the rail route have the same concern, maybe somebody will listen.

You can also tell the Corps whether noise mitigation measures will make the impacts “less than significant” for you.  Some possibilities include:

• Creating “quiet zones,” where whistles aren’t required.  Unless We the People want to pay for this to happen, point out that it’s an impact of the project that must be paid for by the project sponsor.  Quiet zones won’t reduce “wayside” noise, but they can reduce train whistle noise.
• Soundproofing your house – for those who don’t mind sleeping with their windows closed and who never sit outside.
• A before/after assessment :  An assessor can determine the value of the property before the use, the value of the property after the use, and the project proponent then makes up for the difference.

Of course, a before/after assessment doesn’t address every impact.  Nothing has been built yet on the waterfront, for example.  What kinds of costs will noise and vibration impose on those future homes and businesses, and how can those impacts be mitigated?  Perhaps the project applicant should put funds into escrow, to help reduce the cost burden on new businesses downtown. 

 
If citizens demand to be treated as if they are “significant,” will the agencies have to agree?  They might not.  But even if the agencies ignore people's concerns, even if the courts won’t step in, your elected representatives ought to care.

Many of our current elected officials, as well as most of those running for office, have stated that they don’t have a position on the Gateway Pacific Terminal.  They’ll just wait and see what the environmental impact statement says.

And that’s fine, as long as the EIS measures what matters.  And doesn’t leave a great big steaming pile of “non-significant” impacts for just plain folks to live with.

Every public figure who is going to “wait and see” about one of the largest projects ever to take place on our continent has an obligation to make sure that his or her constituents matter.

So tell them. 

In your scoping comments, tell the agencies how noise affects you. And while you're at it, why not send those comments to your elected officials – federal, state, and local.  They need to know.

And yes, that includes the County Council.  

There is nothing about a request for an appropriate standard of environmental review that requires Council members to be "for" or "against" the project.  In fact, project proponents have repeatedly stated that this will be a rigorous review.   County Council members will be using this information to make their decision, so they ought to be confident that they will get the information that they need.  That's only "fair."