Grays Harbor Oil-by-Rail Projects – Comments due November 30, 2015



Two projects that need our attention

Two existing and adjacent terminals in Grays Harbor, Westway and Imperium, want to expand their facilities to bring in crude oil by rail to their project sites where they will load it onto tankers and tank barges “for shipping to refineries on the West Coast and potentially abroad.”

More than 22,000 scoping comments (including one from San Juan Islanders for Safe Shipping) were submitted in May 2014 for these proposed terminals.

Those scoping comments were used to craft the newly released Draft Environmental Impact Statements (DEISs) for the projects, and they are now ready for our responses. 

This is our opportunity to ask that our islands and the health of the Salish Sea be considered and included in the Final Environmental Impact Statements (FEISs).

“An increase in orcas and salmon, please — not tankers and tank barges!”



1. The DEISs include all the vessel traffic from these proposed projects in Grays Harbor entering the Salish Sea. This could be for bunkering (vessel fueling) purposes and/or to deliver crude oil to the refineries. If these projects are permitted, 638 additional crude oil tanker and tank barge transits would be passing through the Salish Sea each year. More vessel traffic means more risk of a major oil spill, therefore, we ask that the FEISs thoroughly address all of the projects’ potentially adverse impacts to San Juan County’s water environment, economy, and all of its species (human and otherwise).

2. San Juan County’s tourism economy is inseparably linked to a healthy and sustainable salmon fishery and Orca population — where there is salmon, there are Orcas. “Our” Southern Resident Killer Whales (SRKW) have been tracked by NOAA to the mouth of Grays Harbor where the salmon rivers of the Humptulips, Satsop, and Wynoochee empty (see tracking map below). For not only the SRKW and salmon, we ask that the FEISs address all potential adverse impacts to all the 119 species-at-risk in the Salish Sea, their migratory pathways and their critical habitats.


NOAA Tracking Map – SRKW @ Grays Harbor, April 2015


3.  San Juan County jobs are directly tied to our SRKWs and also to fishing and shell fishing, both commercial and recreational. The Treaty of Point Elliott of 1855 guarantees the tribal “right of taking fish at usual and accustomed grounds.” For these important facts, we ask that the FEISs thoroughly address oil spill risk and associated adverse impacts to tribal treaty protected rights in the Salish Sea, and all adverse impacts to tribal, commercial, and recreational fishing and shell fishing.

4. The projects’ current plans are to receive crude oil by rail from the Bakken fields in North Dakota or Canadian tar sands/diluted bitumen. We ask that the FEISs require oil spill contingency plans to include the proper equipment and personnel to respond to a spill of the especially volatile, sinkable, and toxic Canadian oil sands/bitumen crude. Please study the impacts of a spill of this particular type of oil. Please identify worst-case spill scenarios and the associated cleanup costs of this particular type of oil.

5. According to the San Juan County Economic Development Council, the quality of San Juan County’s marine environment and natural resources are major drivers of the tourism, construction, real estate, and retail industries that represent nearly 80% of San Juan County’s total economy. A projects-related oil spill in the Salish Sea would have a devastating effect on our islands’ economic well-being and quality of life. The projects would bring 139 operational jobs to the Grays Harbor community, but at what risk to the rest of the region’s jobs that depend upon our marine ecosystem? We ask that the FEISs include cost-benefit analyses for all the cities and counties that would be affected by the proposed projects, including the costs associated with oil spills, and Canadian oil sands/diluted bitumen spills in particular.

6. These two projects do not exist in a bubble (there is yet a third Grays Harbor oil-by-rail project awaiting its DEIS). The vessel traffic they would produce, combined with the current vessel traffic projections for projects within the Salish Sea, would increase projected commercial shipping traffic by 48 percent (above 2013 levels).We ask the FEISs to include a cumulative impacts analysis of all existing, new, and “reasonably foreseeable” (proposed) vessel traffic in the Salish Sea.



By mail:

Westway and Imperium Terminal Services Expansion Projects EISs

c/o ICF International

710 Second Street, Suite 550

Seattle, WA 98104


The comment period ends November 30, 2015.

(Note: the comment period was recently extended from October 29 because people asked for more time. See? They really do listen!)



Both Draft EISs are available on the Ecology website:

Comparison of Westway and Imperium Expansion Projects Fact Sheet:

Officials hear overwhelming opposition to crude

“Locals and people from across the state voiced their fears and concerns about the possibility of the shipment and storage of crude oil on Grays Harbor Thursday during the second and final public comment period for the proposed crude oil storage facilities at the Port of Grays Harbor…Opponents of oil far outnumbered supporters of the projects…”

Washington is (still) unprepared for a Grays Harbor oil spill

“…because the [Nestucca] spill happened just a few months before Exxon Valdez…Grays Harbor’s smaller disaster was largely forgotten…After the Nestucca spill, cleanup workers collected 13,000 oiled birds out of the estimated 52,000 to 78,000 that were impacted. Only 1,000 survived…Today, Washington has the capacity to treat less than 1 percent of the number of birds recovered after the Nestucca spill.”

The impacts of a Grays Harbor oil spill

“Three large oil terminals proposed for Grays Harbor could undermine the region’s economy and local culture.”

Grays Harbor ship traffic: the impact of oil plans

“…Westway and the Imperium…already store around one million barrels of fuels and liquids like methanol, biodiesel, and canola oil. Their oil expansion plans, plus those of US Development nearby, would more than triple the amount of storage tank capacity for crude.”

NOAA 2015 Southern Resident Killer Whale Satellite Tagging

Puget Sound’s killer whales looking good [Note: keep reading]

“A 2014 special report by NOAA…pointed to limited salmon populations, vessel traffic and noise, and chemical contamination as the main threats to the whales. They have been listed for protection under the Endangered Species Act since 2005 but their numbers have continued to decline.”


Sightline’s Eric de Place talks about fighting dirty energy projects in the PNW. At 7:20 he begins showing a series of maps locating all the new and proposed fossil fuel projects in our region (the oil-by rail map is at 8:17). At 40:52 he outlines the successful efforts of groups and individuals to fight these projects and make the PNW “the place where energy projects go to die.” We do make a difference, Safe Shippers!



1. The Draft EIS for Tesoro Savage crude-by-rail facility on the Columbia River at Vancouver, WA is due out in November 2015. Safe Shippers have submitted comments in the past about our concerns regarding this project (many similar to those of the Westway and Imperium projects, as mentioned above). This next step will be to make sure that our concerns as islanders are addressed in the Draft EIS and included in the Final EIS.

2. The Draft EIS for Millennium Bulk Terminal’s proposed coal export project in Longview, WA is due out in Spring 2016. This project would bring 16 new trains daily, and 840 additional ships on the Columbia River annually. Safe Shippers’ scoping comments were among the over 215,000 comments received in November 2013. We will have our chance to review the Draft EIS and make sure our concerns as islanders are addressed in the Draft EIS and included in the Final EIS.

These comment periods are our chance to stop these projects, Safe Shippers. Keep those typing fingers limber!