An Open Letter to the Bay Area Air District

Dear BAAD Directors and staff:

We are individuals and organizations who live and work in the Bay Area Air District. We urge the Air District to fully exercise its permitting, regulatory, and enforcement authority to prevent increased fine particulate matter (PM 2.5) emissions from coal transport through the planned Oakland Bulk and Oversized Terminal (OBOT). Coal shipment to and through a facility adjacent to the Bay Bridge Toll Plaza would significantly harm the health of Bay Area residents, both in the immediate vicinity of the facility and all along the rail route from Martinez to Oakland. At particular risk are the West Oakland and Richmond/North Richmond/San Pablo environmental justice communities who collaborate with you on Community Emissions Reduction Programs.

In a peer-reviewed study published in Air Quality, Atmosphere & Health (March 2023) [1], Dr. Bart Ostro quantified “the contribution to ambient PM2.5 from uncovered railcars that convey coal predominantly from mines in Southern Utah to the Levin Terminal in Richmond, California” and found “significant increases in PM2.5 due to passing coal-carrying trains.” The study concluded that “shipment of coal by train […] represents a significant public health hazard.”

In the Executive Summary of the authors’ report [2] to the California Air Resources Board [3], Dr. Ostro and his co-authors enumerated their conclusions:

Coal Transport Increases PM2.5 – “Rail conveyance of coal significantly increases ambient concentrations of PM2.5. … more than freight trains.”
Unloaded Coal Cars Increase PM2.5 – “Rail transit of unloaded [coal] cars increases ambient PM2.5 concentrations.”
Coal Storage Increases PM2.5 – “Storage of coal and coal cars at the rail yard significantly increases ambient concentrations of PM2.5.” This is true for both full and empty coal cars, both of which increase PM2.5 concentrations over regular freight trains.
Coal Terminal Operations Increase PM2.5 – “Terminal operations involving coal transport, storage, and handling, significantly increase community exposure to ambient PM2.5,” with the presence of coal in the community independently detected.
Negative Health Impacts Result from These Increases in PM2.5 – “These PM2.5 increments subsequently increase the risk of a wide range of adverse health effects with environmental justice implications for the exposed population, as the adverse effects are borne disproportionately by the most vulnerable, including infants, children and the elderly, people of color, those with low incomes, and those with underlying health conditions.”

Ostro, et al. published a related peer reviewed study in Environmental Research (July 2024) [4], “Health impact assessment of PM2.5 from uncovered coal trains in the San Francisco Bay Area: Implications for global exposures,” a quantitative analysis of expected health impacts on Contra Costa and Alameda County residents due to the passage of trains carrying coal mined in Utah along the rail corridor from Martinez to Oakland as proposed by OBOT. The study’s results include elevated instances of lung disease, pneumonia, stroke, cardiovascular disease, asthma, and premature mortality (Sec 4., Results).

This body of scientific evidence aligns with concerns raised during earlier legal proceedings related to OBOT.

In July 2016, the City of Oakland enacted an ordinance to prohibit the storage and handling of coal and petcoke at bulk material facilities or terminals and a resolution applying that ordinance to OBOT. U.S. District Court Judge Vince Chhabria ruled in a May 2018 decision [5] that the City violated its contract with developers in applying the ordinance to OBOT, nullifying the resolution.

The judge’s conclusions relied on developers’ mitigation plans and commitments and on “the broad scope of the Air District’s regulatory power.” (Chhabria, 24). Judge Chhabria noted:

“The project developers submit that they are willing to obligate themselves to accept only coal that is carried to the terminal on covered rail cars.” (Chhabria, 14).
“And the Air District’s Director of Planning testified before the City Council in September 2015 that the City should require covers on OBOT’s coal cars (as well as its conveyors, storage, and other operations), suggesting their viability.” (Chhabria, 15).
“OBOT would use control technology that would be 99 percent effective in mitigating emission.” (Chhabria, 21).
“[T]he Air District could also require OBOT to limit emissions by using rail car covers, surfactants, and other controls.” (Chhabria, 23).
“Most significantly, the Air District could impose permitting conditions that would limit the amount of coal that could be processed at the terminal” (Chhabria, 23).

Alarmingly, it has recently come to light [6] that OBOT has been courting producers of lower grade coal sourced from Wyoming and Montana which is “far dustier and likelier to emit particulate matter than western bituminous coal from Utah.” (Chhabria, 26). As reported in a December 2025 news article [7], Drew Perkins, Wyoming Governor Mark Gordon’s chief of staff, opined that “[t]hey’re probably looking for at least 20 million tons of coal to burn in Taiwan a year.” That quantity of Wyoming’s Powder River Basin coal would double or quadruple the five to ten million tons per year sourced from Utah that developers acknowledged was their plan at the time of the 2018 federal trial. This would severely exacerbate health impacts.

With developers proceeding at speed to secure permits and build a coal terminal, residents and workers rely on the full range of the Air District’s expertise and authority to protect our health and safety. To that end, we ask you consider the following suggestions from community members:

Set stringent emissions limits aligned with the West Oakland and Richmond Community Emissions Reduction Plans;
Cap the total volume of coal handled, especially if any Powder River Basin coal is involved;
Hold the developers to their own proposed mitigation measures that were persuasive to Judge Chhabria, including requiring enclosure of the entire facility, covered rail cars, surfactants, “bottom-release rail cars to unload the coal into underground dust collection systems, and […] enclosed conveyance systems with dust control technology” (Chhabria, 21);
Deploy comprehensive baseline air monitoring well before construction, ideally in partnership with residents, schools, and community institutions;
Require all terminal machinery to be zero-emission;
Require zero-emission locomotives for all local rail movements; and,
Implement strong enforcement measures ranging up to immediate shut-down for excessive emissions and strict remediation deadlines.

We urge the Air District to evaluate each OBOT permit application with the utmost care and to include regulatory conditions that reflect (1) the best available emission reduction technology; (2) developer plans and commitments that were instrumental in convincing a federal district court judge to allow OBOT to handle coal; (3) the large population that will be exposed; and, (4) existing cumulative pollutant burdens and community vulnerabilities. Bay Area residents are counting on the District to protect our health and safety.

Signed,

Organizations

1000 Grandmothers for Future Generations
350 Bay Area
350 Silicon Valley
Albany Climate Action Coalition
Asian Pacific Environmental Network
Bay Area-System Change not Climate Change
BayPorte Village Neighborhood Watch
Biofuelwatch
Breast Cancer Prevention Partners
California Interfaith Power & Light
Californians for Energy Choice
Care 4 Community Action
Citizens’ Climate Lobby, Alameda County
Citizens for East Shore Parks
Climate Health Now
Climate Justice Committee, Unitarian Universalist Church of Berkeley
Communities for a Better Environment
Contra Costa MoveOn
East Bay Democratic Socialists of America
East Bay Permanent Real Estate Cooperative
EcoEquity
Elders Climate Action Northern California Chapter
Extinction Rebellion San Francisco Bay Area
Faith in Action East Bay
Food Empowerment Project
Fossil Free California
Frontline Catalysts
Green Party of Alameda County
Green The Church
Greenaction for Health and Environmental Justice
Healthy Martinez
Indivisible Berkeley
Industrial Workers of the World (IWW), Bay Area General Membership Branch
Interfaith Council of Alameda County
International Human Rights Clinic, Santa Clara University School of Law
International Longshore & Warehouse Union Local 6
Justice Council, First Unitarian Church of Oakland
Labor Rise Climate Jobs Action Group
Local Clean Energy Alliance
Making Preparation for Afrikan Reparations
No Coal in Oakland
No Coal in Richmond
Oakland Peace Center
Oil and Gas Action Network
Oil Change International
Our City San Francisco
Peace and Freedom Party Alameda County
Prison Activist Resource Center
Reclaim Our Power: Utility Justice Campaign
Richmond Shoreline Alliance
San Francisco Bay Physicians for Social Responsibility
San Francisco Baykeeper
Service Employees International Union (SEIU) Local 1021
Skyline Community Church
Spokeland
St. Columba Catholic Church
Stop OAK Expansion Coalition
Sunflower Alliance
Sunrise Movement Bay Area
Sustainable Mill Valley
Transition Berkeley
United Native Americans
Wellstone Democratic Renewal Club
West Berkeley Alliance for Clean Air and Safe Jobs
West Oakland Cultural Action Network (WOCAN)
West Oakland Environmental Indicators Project
West Oakland Neighbors
Youth Vs. Apocalypse

Individuals

Businesses

Greenbank Associates
QT Nightlife
We Can Do It Plumbing

[To add your name as an individual endorser, visit the Individual Sign-on page (a Google Form). Organizational signers are invited to use the Organizational sign-on form (also a Google Form).]

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[1] Ostro, B., Spada, N. & Kuiper, H. The impact of coal trains on PM2.5 in the San Francisco Bay area. Air Qual Atmos Health 16, 1173–1183 (2023). https://doi.org/10.1007/s11869-023-01333-0

[2] Assessment of Coal and Petroleum Coke Production: Air Quality, Health, and Environmental Justice, April 26, 2023. https://ucdavis.app.box.com/s/sh55sgeix0r39k07zfsai1tcamux8qpw

[3] The study conducted by Dr. Ostro, et al., was funded by the California Air Resources Board.

[4] Ostro, et al. Health impact assessment of PM2.5 from uncovered coal trains in the San Francisco Bay Area: Implications for global exposure. https://doi.org/10.1016/j.envres.2024.118787

[5] Findings of Fact and Conclusions of Law, Oakland Bulk & Oversized Terminal, LLC v. City of Oakland, Case No. 16-cv-07014-VC, United States District Judge Vince Chhabria, May 15, 2018. A copy of Judge Chhabria’s decision can be accessed at https://nocoalinoakland.info/wp-content/uploads/2018/05/Oakland-Coal-Decision-5-15-2018.pdf

[6] “California Supreme Court Clears Path For Wyoming Coal Exports Through Oakland Port,” Cowboy State Daily, September 18, 2025 https://cowboystatedaily.com/2025/09/18/california-supreme-court-clears-path-for-wyoming-coal-exports-through-oakland-port

[7] “Wyoming Bets Big On Coal Exports To Asian Energy Markets,” Cowboy State Daily, December 1, 2025 https://cowboystatedaily.com/2025/12/01/wyoming-bets-big-on-coal-exports-and-asian-energy-markets/

An Open Letter to the Bay Area Air District

Organizations

Individuals

Businesses

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