Utah Inland Port Comments to the Environmental Justice Advisory Council

Utah Physicians for a Healthy Environment, and the 450 physicians and 3,000 members of the lay public within the organization, congratulates the Biden Administration for giving the issue of environmental justice long overdue attention. But the Administration should not just focus existing on injustice, it should also try to intervene and prevent projects that are destined to become monuments of future environmental injustice.

One such project being designed and given hundreds of millions of dollars of tax payer money by our legislature, is the Salt Lake City inland port. This is a massive transmodal shipping hub and warehouse farm now planned for the Westside of Salt Lake City, in the immediate vicinity of 250,000 people who already suffer the most pollution and environmental toxin exposure of the 2 million people who live in the SL Valley.

They suffer the traffic pollution of our busiest freeways, are immediately downwind of several oil refineries, near an enormous open pit copper mine and smelter, downwind of summer-long aerial spraying of pesticides, numerous industrial smokestacks, are downwind of a major international airport and secondary airport whose planes still use leaded gas. None of this would be tolerated on the East side of Salt Lake City, but because of lack of political clout, the Utah legislature is shoving this down the throats of those who are already the most victimized by our numerous pollution sources.

This transmodal shipping hub would be the epicenter of multiple new sources of pollution–an estimated 70,000 more daily diesel truck trips, diesel powered switcher engines, 150,000 more cars, increased air traffic pollution, more pesticide spraying, and dozens more train locomotives (incidentally one Tier 0 train locomotive can emit pollution equal to that from around ten thousand cars). This project clearly exploits the economic, and racial disadvantages of this community, and Utah politicians remain unflinching in their determination to push it forward. 

Other inland ports and warehouse farms, smaller than what is planned in SLC, are now nicknamed “Diesel Death” zones because of the pollution they generate. There is absolutely no reason to think that developing one in Utah will produce a different outcome.

This port is also intended to facilitate more fossil fuel extraction, something squarely contradictory to the Biden Administration’s climate goals.

The rationale being offered that the port is needed to produce jobs is a smoke screen. Utah historically has a very tight labor market, the current unemployment rate is 2.4%, and most of the anticipated port employment will be low wage warehouse jobs. The real beneficiaries are well connected developers and powerful international corporations eager to exploit this community for profit.

Using the Clean Air and Clean Water Acts, several federal agencies could intervene and prevent this injustice from happening. Dealing with the obvious consequences after the fact will only further victimize this community.

We believe that the EPA can use tools within the Clea Air Act to prevent this project. More specifically, the forces behind building this inland port intend to dilute public opposition, and to evade regulatory review and the protections that might be afforded through the CAA, by building this project piece meal. In other words, it seems that by refusing to present the inland port project in its entirety or estimate its emissions, proponents are keeping the extent and details of their ultimate plans secret and will instead complete the project incrementally such that each of these smaller projects will escape the review, analysis, well-informed decision making and public participation that would otherwise be directed at the whole project.

This is “death by a thousand cuts”

We are particularly concerned that the Inland Port will never be subject to meaningful review based on its impacts on air quality – particularly on ozone and PM2.5 concentrations – and on environmental justice and disproportionately impacted communities.

More specifically, we ask the EPA:  will NEPA, general and transportation conformity (required by the Clean Air Act) and 404 (CWA) apply to this project?