Dear Safe Shippers,
We have an opportunity to take direct action in support of Southern Resident orcas!
Phillips 66 Ferndale Refinery (Phillips 66) wants to construct a new 300,000 barrel crude oil storage tank and a new 80,000 barrel fuel oil storage tank, just a short orca swim across the Salish Sea from our islands. These new storage tanks would provide flexibility for Phillips 66 to manufacture a new product – low sulfur marine fuels – to meet the International Maritime Organization (IMO) 2020 sulphur cap regulation.
Whatcom County has determined “that with proper mitigation, no significant adverse environmental impacts are likely” from this project (see their State Environmental Policy Act (SEPA) Mitigated Determination of Nonsignificance (MDNS)).
“No impacts”? What about the orcas? What raises red flags for Safe Shippers about this determination is that Phillips 66 did not provide direct answers regarding the additional vessel traffic associated with this project, and Whatcom County did not address the additional vessel traffic’s impacts to Southern Resident Killer Whales, including increased oil spill risk.
The Phillips 66 Refinery, including its marine terminal, is located on the shores of the Area 1 – Summer Core Area of the Designated Critical Habitat for Southern Resident Killer Whales. And yet…the critically endangered Southern Residents are not even identified in the SEPA checklist, in spite of the explicit requirement to “list any threatened and endangered species known to be on or near the site” (WAC 197-11-960(5)(b)). Additionally, Whatcom County’s MDNS does not even consider whether the project will adversely affect Southern Resident Killer Whales or their habitat (WAC 197-11-330 (3)(e)(ii)).
Large commercial ships do cause significant adverse impacts on our fragile Southern Residents. Among them are: disruption of orcas’ echolocation ability to communicate and successfully hunt for scarce prey; direct vessel strikes; vessel noise-induced hearing loss and behavioral changes; and the risk of major oil spills. Regarding oil spills…Southern Resident Killer Whales were listed as endangered under the Endangered Species Act, in part, because of concerns about potential oil spill impacts. A report on the orcas from the National Marine Fisheries Service states, “Their small population size and social structure also puts them at risk for a catastrophic event, such as an oil spill, that could impact the entire population.” These impacts must not be ignored!
What can Safe Shippers do in support of the whales?
Ask Whatcom County to reconsider the MDNS threshold determination and:
1. Require Phillips 66 to provide details on the marine vessel traffic associated with the manufacture of low sulfur fuel oil products.
2. Specifically address the project’s vessel traffic’s adverse impacts to the critically endangered Southern Resident Killer Whales.
3. Specifically address the project’s vessel traffic’s increased oil spill risk and associated adverse impacts to Southern Residents and also the Salish Sea ecosystem and neighboring communities.
4. Ensure that this MDNS does not result in inappropriate piecemeal development at the Phillips 66 Ferndale Refinery.
For inspiration, see the comment letter submitted by Friends of the San Juans.
Please submit your comments via e-mail by 4:00 pm on Friday, August 2, 2019 Mr. Thomas Brissenden, Whatcom County Natural Resources Planner E-mail: firstname.lastname@example.orgUse the subject line “File: SEP2019-00033.”
Please also contact Governor Jay Inslee’s officeCall (360) 902-4111 (M-F 8:00am-5:00pm; press 1 to bypass the intro message) Or, send an e-message.Ask the Governor to ensure that the permitting process for the Phillips 66 Ferndale Refinery’s new storage tanks thoroughly addresses the project’s adverse impacts to Southern Resident orcas.
Tell Whatcom County and Governor Inslee why the protection and recovery of the Southern Residents are important to you.
Thank you, Safe Shippers, for taking action in support of our Southern Resident orcas!
Argus: “Phillips 66 modifies refineries for marine fuel rule”https://www.argusmedia.com/en/news/1924837-phillips-66-modifies-refineries-for-marine-fuel-rule
Journal of the San Juan Islands: “Tanker traffic continues to increase through Salish Sea”https://www.sanjuanjournal.com/life/tanker-traffic-continues-to-increase-through-salish-sea/
The Seattle Times: “The Roar Below”https://projects.seattletimes.com/2019/hostile-waters-orcas-noise/