Help save Puget Sound from BP’s dirty oil business!

Oil giant BP is free to drastically expand oil tanker traffic to its Cherry Point oil refinery, threatening the Sound’s surrounding communities and marine life unless we take action to stop it.

Puget Sound’s economy and the Indigenous communities who live nearby will be harmed if BP is allowed to expand its oil refinery with no limits. An oil spill would decimate the Sound’s fish populations that provide tribal communities with nutritional and cultural sustenance. And the tourism industry that many community members work in and run businesses around would be devastated.

More oil tankers in this fragile ecosystem is a recipe for disaster. One oil spill and the Sound might never look the same. We’re running out of time to stop BP – but there’s still hope.

Comments

Dear Mr. Krenz:

More than eight years have passed since the close of the comment period for the draft environmental impact statement for the BP Cherry Point Dock, and yet the concerns raised back in 2014 have not been addressed in the Final Environmental Impact Statement (FEIS). The FEIS continues to rely on incomplete and stale data, fails to consider vessel traffic from currently proposed and reasonably foreseeable projects and actions, and fails to adequately describe the Proposed Action or consider a specific alternative that complies with the Magnuson Amendment. In fact, the FEIS takes a major step backward from the DEIS.

1.	The FEIS relies on stale and incomplete data

The Army Corps’ failure to use the most up-to-date information and tools available undermines the public’s confidence in an EIS and renders the FEIS defective. The Corps should have updated the FEIS analysis with more recent vessel traffic data. The Corps failed to evaluate oil spill risk in the context of the maximum physical capacity of the expanded dock. In addition, the FEIS should have included vessel traffic from seven proposed projects in the region in its cumulative impacts analysis.

2.	The FEIS misrepresents the data regarding vessel traffic

The FEIS analysis of the vessel traffic data is conducted in such a way as to obscure the impact of changes in tank vessel calls resulting from the construction of the North wing of the dock, as well as the expansion of the Puget Sound Pipeline and rail infrastructure.

3.	The FEIS fails to adequately describe the proposed action or consider a specific alternative that would comply with the Magnuson Amendment.

The “Proposed Action” identified in the FEIS does not, in fact, disclose what action the Corps intends to take—rather, the FEIS only states that the Corps “would likely modify the existing permit by adding any appropriate and practicable permit terms and conditions that are necessary to comply with applicable laws and regulations and protect the public interest.” The Magnuson Amendment requires a limit on the number of crude vessels that can utilize the entire dock.

4.	The FEIS is deficient and should not be used to justify BP’s North wing. The Army Corps must limit the number of crude vessels that can utilize the dock in its Record of Decision

The FEIS is defective under NEPA because it relies on incomplete and stale data, fails to consider vessel traffic from currently proposed and reasonably foreseeable projects and actions, fails to account for documented increases in refinery capacity, and fails to adequately describe the Proposed Action or consider a specific alternative that complies with the Magnuson Amendment. Even still, the data show an increase in vessel calls at the terminal since the construction of the North wing. The Magnuson Amendment requires a limit on the number of crude vessels that can utilize the entire dock, and the Army Corps must modify BP’s permit conditions to address this when the Corps issues the Record of Decision and Magnuson Amendment determination.

Thank you,
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