January 22, 2016

Sonia Bumpus, EFS Specialist, & EFSEC Members

Energy Facility Site Evaluation Council (EFSEC)

State of Washington

1300 S. Evergreen Park Drive SW

P.O. Box 43172

Olympia, Washington 98504-3172

sbumpus@utc.wa.gov

Sent via email and attachment

WIRT Comments on Tesoro Savage Vancouver Energy Project Draft Environmental Impact Statement

Members of the Energy Facility Site Evaluation Council,

On behalf of over 3200 members, friends, and allies of Wild Idaho Rising Tide (WIRT), including potentially impacted, concerned north Idaho residents near the proposed and existing rail routes affected by this proposal, I respectfully offer and request inclusion in the public record of these comments regarding the Tesoro Savage Vancouver Energy Project draft environmental impact statement (DEIS), during the public agency and citizen review period from November 24, 2015, until January 22, 2016 [1]. WIRT and associates collectively object to state permitting of the Tesoro Savage oil train terminal planned for the Port of Vancouver, Washington, which would impart myriad, significant risks and only marginal rewards for communities along the rail tracks and bridges, rivers, and lakes of Tesoro’s and Savage’s profitable thoroughfare to crude oil export.  In support of this official letter of resistance to Washington state Energy Facility Site Evaluation Council (EFSEC) approval of this application and resulting, destructive, implementation activities, we thoroughly concur with, contribute toward, and incorporate the concerns, oral testimony, and comments of all project opponents.

The Tesoro and Savage corporations intend to build the biggest crude-oil-by-rail terminal in the U.S. at the Port of Vancouver, potentially transferring an estimated 360,000 barrels per day of explosive Bakken shale oil and volatile Alberta diluted bitumen (tar sands) to tank farms across the Columbia River from Portland, Oregon, and to huge, ocean-going oil tankers shipping it to West Coast refineries and the world market [2]. Inevitable, disastrous, consequent oil spills into river, lake, or sea waters along rail and ocean routes, especially releases of thick tar sands oil that sinks to the bottom of waterways, would devastate local and regional waters and environments, fisheries, tribal lifeways, communities, and economies.

While moving enormous volumes of oil that ultimately impact our shared global climate, the Tesoro Savage facility would also increase the risk of fiery oil train accidents in countless communities along Northwest rail lines, from the Hi-Line around U.S. Highway 2 in Montana, to U.S. Highway 95 corridor towns from Bonners Ferry to Rathdrum in northern Idaho, to the dangerously elevated bridge and track funnels through the Sandpoint, Idaho area and downtown Spokane, Washington, to the Columbia River Gorge between eastern Oregon and Washington, to Vancouver [3, 4]. Every day, the huge oil terminal would bring four or more 100-car, mile-long trains toward the West Coast, hauling flammable cargo through climate-change-drying forests, increasingly dense cities, and ever more precious water bodies.  Public officials and emergency responders across the Northwest have raised concerns about the severe threats of oil train derailments, explosions, and pollution, as such incidents continually proliferate [5-7].

Many WIRT and allied group members who carpooled from Moscow and Sandpoint, Idaho, and Pullman, Washington, participated in the regional community rally of terminal opponents and orally testified at the public hearing on the project’s DEIS, hosted by EFSEC on Thursday evening, January 14, 2016, in Spokane Valley, Washington [8-10]. These activists spoke against the Tesoro Savage proposal, the deficiencies of its DEIS findings, greater hazards imposed by this massive project of significant oil spills, air pollution, loaded train derailments, explosions, fires, and accidents causing numerous injuries and deaths, increased rail and waterway traffic of oil tankers, harm to federally protected salmonids and aquatic species, detrimental effects on tribal treaties, cultures, and resources, susceptibility of the facility to earthquakes, more and longer vehicle delays at railroad crossings, and overall exacerbation of climate change [11].  These myriad, significant, environmental, social, and human health harms cannot be fully mitigated by the project proponents or local, state, and federal agencies.  Moreover, the project DEIS does not even consider the predictable potential impacts of this oil terminal beyond Washington state.

Northwesterners have successfully delayed, re-routed, and/or stopped similar fossil fuel infrastructure plans over the last five years, most notably tar sands mining and refining megaloads, coal export terminals, and just this month, a Grays Harbor oil terminal [12]. Faced with a flood of proposed coal, oil, tar sands, and liquefied natural gas terminals in the Pacific Northwest, hundreds of concerned citizens have attended hearings to tell EFSEC decision-makers no [13].  Native nations, civic groups, neighborhood associations, faith and business leaders, health and emergency professionals, firefighters, longshoremen, environmental organizations, grassroots conservation and climate activists, and other amazing, local heroes among a coalition of Northwest groups, as well as the cities of Portland, Sandpoint, Spokane, and Vancouver, have together formally opposed and delayed nine fossil fuel terminals and stopped nine others in Oregon and Washington.

Contrary to the mandates of the Washington State Environmental Policy Act (SEPA), the DEIS insufficiently provides the basis for rational public and agency evaluation and decisions about this project’s predictable adverse impacts, questionable benefits, and un- or under-explored alternatives for energy development. The huge document contains numerous deficiencies, including inaccuracies, misstatements, and errors, as well as omission of substantive responses to citizen comments, in addition to the absence or misrepresentation of data and its analyses.

Tesoro’s and Savage’s unprecedented, reckless proposal is prompting mounting, contentious pressure from constituents across the inland Northwest, who are incrementally but successfully protecting the safety, health, and environment of the Idaho panhandle, western Montana, and beyond, by resisting this oil terminal and its additional trains crossing the region. Although jumping through government/industry-imposed hearing and comment period hoops held up to placate the public is not radical climate activism – wherein citizens, not their oppressors, define the terms of engagement – Wild Idaho Rising Tide activists and members strongly urge you, as Washington EFSEC members advising decision-maker Governor Jay Inslee, to reject this dirty and dangerous Tesoro Savage oil terminal.  We also encourage several corrective courses of action for EFSEC, not to buttress the legal defensibility of yet another NEPA document that ushers in more environmental and social destruction, but to support in good faith an appropriate review of the Tesoro Savage Vancouver Energy Project, before issuance of its final environmental impact statement.  We urgently request that EFSEC acknowledge and accommodate the best interests of ALL Northwesterners, including Idahoans, by addressing several issues completely overlooked by the project DEIS:

1) Prepare a supplemental draft environmental impact statement, without the assistance of industry-biased researchers and authors [4]. Displaying blatant conflicts of interests through their ties to the railroad companies, who would benefit with heightened business opportunities from this terminal, the crafters of this DEIS did not fairly represent the concerns of Northwesterners in this environmental review.

2) More closely examine citizen-suggested alternatives offered during the project scoping phase but not considered in the DEIS. For example, Northwest states are rapidly transforming public power supplies from economically and environmentally risky fossil fuels, such as the oil, gas, and tar sands production augmented by this project, into emerging modes of safe, clean, renewable energy, as responsive solutions to the current climate crisis.

3) Study the separate and compounded damages imposed by the increased fossil fuel extraction, transportation, production, and combustion that this project enables, all exacerbating climate change, for instance its fuel stock drilled and/or mined in Alberta, British Columbia, Montana, North Dakota, and beyond, and its pollution implications for world market destinations. The Washington Department of Ecology has similarly enlarged the scope of its review of the Gateway Pacific terminal, the largest coal export facility proposed for North America [14].

4) Geographically expand this environmental review, to analysis the cumulative impacts to Idahoans, Montanans, North Dakotans, Oregonians, Canadians, and other populations and their resources jeopardized by the Tesoro Savage oil terminal proposal, including climate changed plant and animal habitats, unique environments, and vulnerable watercourses near rail lines. Idaho and Montana groups who sent speakers to the January 14, 2016 Spokane Valley public hearing, from Billings, Bozeman, Helena, Livingston, Missoula, Moscow, Sandpoint, and other towns across these states demand appropriate Washington state government consideration of inland Northwest concerns neglected in the current DEIS [11].

5) Accordingly, extend the public comment period on this project and make publicly available all associated records, to accommodate greater opportunities for public involvement necessitated by a combination of intense public interest, the size and intricacies of the DEIS, and the consequent time required for informed public review and reasonable discussion.

When and if all of these methods to redress American grievances with fossil fuel-driven climate change prove ineffective, regional climate activist group WIRT, residing in the Idaho frontline, train transportation bottleneck of Powder River Basin coal, Bakken shale oil, and Alberta tar sands, will continue recruiting rail corridor friends, family, and community members to physically demonstrate to the rail and fossil fuel industries our collective resistance to every dirty energy project affecting northern Idaho and eastern Washington. In the enduring Rising Tide spirit of Flood the System, we are gratefully and eagerly scheming and coordinating upcoming and ongoing direct action training camps, educational workshops, public presentations and discussions, peaceful protests, monthly meetings, weekly broadcast and online radio programs, and other spring and summer 2016 facets of our five-years-running, anti-fossil fuel campaigns, as we chronicle and network with the historic, continent-wide, climate and indigenous justice movements that will stop the Tesoro Savage oil terminal and other new fossil fuel infrastructure [15].

We heartily appreciate your consideration of these comments. Please contact us with any questions or suggestions about this input or further information about the significant, unmitigatable impacts of the Tesoro Savage oil terminal proposed for the Port of Vancouver, Washington.

/s/ Helen Yost, MSEE

Wild Idaho Rising Tide

P.O. Box 9817, Moscow, Idaho 83843

wild.idaho.rising.tide@gmail.com

WildIdahoRisingTide.org

Facebook.com/WildIdaho.RisingTide

Twitter.com/WildIdahoRT

208-301-8039

[1] Tesoro Savage Vancouver Energy Project, Energy Facility Site Evaluation Council

[2] Tesoro Oil-by-Rail Project Report Lists Earthquake, Derailment Threats, November 24, 2015 Portland Business Journal

[3] Largest Oil Terminal in U.S. Would Impact Sandpoint, Susan Drumheller in December 23, 2015 Sandpoint Reader

[4] Critics Say Oil Trains Report Underestimates Risk, December 18, 2015 Spokesman-Review

[5] Why Are So Many Oil Trains Crashing? Track Problems May Be to Blame, October 7, 2015 Los Angeles Times

[6] Railroads Beat Back New Safety Rules after Derailments, December 5, 2015 Associated Press

[7] Truck Hits Train, Tankers Catch Fire near St. Johns Bridge, December 13, 2015 KOIN 6

[8] Please Join WIRT in Carpooling…, December 14, 2015 Wild Idaho Rising Tide

[9] Inland NW Oil Train Terminal Rally and Hearing, January 8, 2016 Wild Idaho Rising Tide

[10] Thanks for Traveling to, Attending, and Testifying…, January 14, 2016 Wild Idaho Rising Tide

[11] Media Coverage of the Tesoro Savage Oil Terminal DEIS Hearing in Spokane Valley on January 14, 2016…, January 19, 2016 Wild Idaho Rising Tide

[12] One of Three Proposed Grays Harbor Crude Oil Storage and Transfer Facilities has Dropped Its Plans! January 7, 2015 Wild Idaho Rising Tide

[13] The First of Three EFSEC Hearings on the Tesoro Savage Crude Oil Storage and Transfer Facility…, January 7, 2015 Wild Idaho Rising Tide

[14] Environmental Review: Gateway Pacific Terminal at Cherry Point Proposal, Washington Department of Ecology

[15] Flood the System, Flood the System