How to Submit Comment on BP Cherry Point Dock EIS

Public Comment Period ends on August 6th!  

Draft EIS re BP Cherry Point North Wing dock:   Following is a compilation of references, resources, and information on how, where and what to comment on this draft Environmental Impact Statement.

For people who don’t want to write a letter, but just want to click their way through one that has been written for them go to RE Sources  or the Climate Solutions letter.

Letters should be addressed to:

Olivia Romano,  U.S. Army Corps of Engineers,
 Seattle District Regulatory Branch
 P.O. Box 3755 
Seattle, WA 98124-3755.

 All comments should include the permit application number NWS-1992-435, as well as your name, address, and phone number.

This news story provides background:

Draft EIS released on previously authorized BP Cherry Point dock North Wing

SEATTLE – The U.S. Army Corps of Engineers today released a Draft Environmental Impact Statement to examine the incremental environmental risk, principally from vessel traffic, related to operation of the  previously authorized addition of the North Wing to the BP Cherry Point dock, near Ferndale, Wash.   The comment period for the draft EIS begins June 6 and closes Aug. 6, 2014. The Corps will hold public meetings in Bellingham and Seattle on July 16 and 24 respectively. Both written and oral scoping comments  will be considered in the preparation of the final EIS.

Public Meeting Dates and Locations: The Corps will hold two public meetings

Bellingham, Wash., July 16, 2014 from 7 to 9 p.m. with open house from 6 to 7 p.m., at the Shuksan  Middle School gymnasium, 2717 Alderwood Avenue, Bellingham, Wash.

Seattle, July 24, 2014: from 7 to 9 p.m. with open house from 6 to 7 p.m. at the Federal Center South,  4735 East Marginal Way South, Galaxy Room, Seattle, Wash.*

The Corps’ scope of analysis for this EIS includes the potential environmental effects of operating both wings (North Wing and South Wing) of the BP Cherry Point dock compared to operating the South Wing at maximum capacity. The EIS also evaluates the risk of potential accidents and oil spills considering vessels carrying crude oil or refined petroleum product while in transit to and from the marine terminal. Three alternatives were analyzed: Proposed Action, No Action and Alternative A.

The Proposed Action is the continued operation of the North Wing, with conditions including prohibiting the use of the North Wing for unloading or loading of crude oil. No Action is revoking the current permit and requiring the removal of the North Wing. Alternative A is identical to the Proposed Action except that the condition prohibiting unloading and loading crude oil would not be included on operations of the North Wing.  During the comment period, the Corps invites federal agencies, state and local governments, Native American Tribes, and the public to participate in the public review process either by providing written comments or by attending the public meetings.

Development of the final EIS will begin after the close of the public comment period.  The Corps was directed by Ninth Circuit Court of Appeals to complete an EIS considering the impacts of reasonably foreseeable increases in vessel traffic due to the addition of the North Wing. The purpose of the EIS is to provide decision-makers and the public with information including the proposed action and alternatives, vessel traffic analyses conducted, the incremental environmental risk related to operations of the  dock, environmental impacts from potential vessel traffic accidents and oil spills in the Puget Sound region,  and the consideration of risk mitigation.

Climate Solutions boiler plate letter:

I am writing to express my concerns about the impacts of the North Wing Pier at the BP refinery on oil and tanker traffic through our communities and waterways. I am concerned about the impacts on the health of Puget Sound and our marine resources. And I am worried about oil train traffic putting our communities at risk.

As it stands now, the Draft Environmental Impact Statement for the second dock at the BP refinery does not adequately assess the risk of its operation.

Please take another look at this draft and ensure it addresses all the impacts and implications of the refinery’s second dock. Specifically:

1)The dock should not result in increased oil tanker traffic to the Cherry Point refinery – for either crude or refined oil. Don’t consider or allow any alternatives that would enable the BP pier or refinery to handle more oil.

2)Develop an alternative that restricts BP’s pier operations to the volume of crude oil and level of vessel traffic observed before the North Wing was built.

3)Require BP to provide to the Department of Ecology and to the public a thorough reporting of both docks’ actual usage in terms of number of vessel calls, products transported including type of oil and origin, as well as all oil-related incidents.

4)Require that spill prevention and response plans are approved and in place before BP begins to receive new types of crude oil or ship new products. As part of this safety measure, that every transfer across the dock is pre-boomed for safety.

 5)The Final Environmental Impact Statement should include a more robust analysis of mitigation for the construction of the dock as well as stronger mitigations for negative impacts from dock operation, including limits on lighting, shading, and operation during herring spawning season.

6)The cumulative impacts of increased tanker traffic from this and all other reasonably foreseeable proposals, including coal, in the geographic area should be adequately assessed and the risks addressed by the Final Environmental Impact Statement.

It is important to get this environmental impact statement right. The above items are key to protecting Puget Sound and improving overall safety of oil transport through our waters.

Thank you.

Note:  The Washington State Council of Firefighters has even called for an outright ban on shipping oil by rail through Washington until we know it’s safe

Comments should address deficiencies in the EIS as they relate to:

  • The cumulative impacts of oil and coal export projects — BP Cherry Point is not operating in a vacuum. It is critical that the EIS do more to assess the combined effects of the north pier’s operations in light of SSA Marine’s proposal to build North America’s largest coal export facility right next door and the potential for added traffic from fossil fuel exports throughout the region.
  • The strength of vessel traffic mitigations — Our vital fishing industry depends on a safe, clean Puget Sound and adjoining waters. The Army Corps has a duty to prevent oil spills, shipping accidents and disruptive activities that destroy the ecosystem supporting our way of life.
  • Preventing the throughput of explosive Bakken crude — The BP north pier must not increase the vessel traffic on Puget Sound. The various expansions of oil-by-rail and pipeline facilities put our community and our waterways at risk.


  • Oil rail shipments are expected to increase in the next few years as a result of the Bakken Oil Shale boom. Many local refineries are proposing rail improvements to handle new traffic. The Bakken formation is projected to deplete quickly at current rates of extraction, so shipping crude by rail is likely to be more capital-efficient for the industry than building new pipelines.
  • What does this mean?   We’ll be seeing more oil trains as the fossil fuel industry works to exploit the latest hard-to-get source of rapidly vanishing oil reserves. It is not entirely clear how many new oil by rail shipments are expected, and when they’ll be coming through our communities. 11 facilities across the Pacific Northwest are currently expected to receive oil shipments by rail; the estimated traffic impact of these proposals is 14 trains per day — 7 full and 7 empty.

Current Status

  • The BP Cherry Point refinery is currently expecting to receive oil shipments. The proposed traffic impact of the proposal is one train per day (or one loaded train every two days).

Oil rail shipments present a number of potential environmental impacts on our communities. These proposals are likely to bring added traffic, the risk of oil spills and derailments, and the burning of oil is a major contributor to climate change. Here are some of the top concerns associated with oil rail shipments:

  • Construction impacts: At most refinery sites, oil rail shipments will require the construction of new rail infrastructure and potentially piers or wharves to accommodate new tanker traffic. The impacts of construction could disrupt wetlands, shorelines and other ecologically critical areas. Typically, wetland mitigation has resulted in a loss of ecosystem functionality, meaning that the wetlands lost to new rail infrastructure construction cannot be easily replaced, if they can be replaced at all.

Combined vessel traffic risks: Oil rail shipments are not happening in a vacuum. If they are pursued alongside proposals for tar sands pipelines, coal exports, and other potential sources of new vessel traffic, the impact on the marine environment will be extremely significant. In addition to dramatically increasing the risk of spills and accidents, added vessel traffic can interfere with wildlife migration patterns, introduce invasive aquatic species and threaten a number of important marine habitats in our region.

  • Climate change: Bakken oil is a fossil fuel, and all of the oil shipments travelling through our community by rail are ultimately destined for combustion. Extraction and use of Bakken oil shale will contribute substantially to the risk of continued climate disruption both locally and globally.
  • Train traffic impacts: Similar to coal export proposals, adding train traffic to serve oil rail shipments means more traffic congestion, infrastructure costs, risk of derailment and air pollution. A derailment in Western Washington could cause serious problems for wildlife, people, communities and ecosystems for many years to come.

The cumulative increase in dirty and dangerous oil and coal trains and tankers in our waters would dramatically increase the risk of a spill or explosion in the Northwest.

Send a message to the Army Corps of Engineers now urging them to protect us from more oil shipments and ensure decisions are not made in a vaccuum!

Marine species, fish or fisheries:

How would the noise, pollution and physical presence of the additional huge vessels affect our orca populations?

How will Chinook salmon will be impacted by a number of factors including harm to the herring that they eat?  The herring that spawn at Cherry Point have a different annual life cycle than other herring, so they are available to eat when other herring are not.

How would the continuous transiting of oil ships affect other marine mammals, fish, birds, and the food web that supports them?

How might fishing and recreational boating be affected by the additional oil ships in our waters? By how much will accident and collision rates increase?

Safety and Other Concerns:

How will  marine vessel traffic increase collision risks with tankers and other cargo ships in the area?

What would be the effects on our region of a catastrophic oil and/or coal spill?

Thanks to Rich V for compiling this information!



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manager of SeattleEnvironmentalActivists' blog
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