Westway Expansion Project Final Environmental Impact Statement

Westway Expansion Project Final Environmental Impact Statement Appendix A – Part 2 September 2016 APPENDIX A Scoping Comments Part 1 Appendix A Scoping Comments Attachment A1 Web-Based Comments Part 2 Attachment A2 Hard-Copy Comment Letters Attachment A2-1 Federal Agencies Attachment A2-2 State Agencies Attachment A2-3 Regional and Local Agencies Attachment A2-4 Tribes Attachment A2-5 Organizations Part 3 Attachment A2 Hard-Copy Comment Letters (continued) Attachment A2-6 General Public Attachment A2-7 Form Letters Attachment A2 Hard‐Copy Comment Letters A2‐1 Federal Agencies May 27, 2014 Imperium and Westway EISs c/o ICF International 710 Second Ave, Suite 550 Seattle, WA 98104 Re: Scoping comments on Westway and Imperium facilities EISs This letter provides comments on scope of the environment impact statements (EISs) required for the proposed Westway Bulk Liquid Facility Project and the Imperium Bulk Liquid Facility Project in Grays Harbor. Olympic Coast National Marine Sanctuary (OCNMS or sanctuary) was designated in 1994 as one of our nations marine protected areas, spanning 3,189 square miles of marine waters off the western Olympic Peninsula. The sanctuary is home to many species of marine mammals and seabirds, diverse populations of kelp and intertidal algae, productive commercial and recreational fisheries and thriving invertebrate communities. Along this coast are hundreds of islands where many of the largest seabird breeding colonies in the region thrive under the federal protection provided by the Washington Islands National Wildlife Refuges. The mainland shore adjacent to the sanctuary is owned by Native Americans (the Makah, Ozette, Quileute, Hoh, and Quinault Reservations) or Olympic National Park. South of the Quinault Reservation, the shoreline is designated as the Washington State Seashore Conservation Area. The Grays Harbor estuary hosts concentrations of wildlife and is a seasonally important feeding or foraging area for wildlife. The estuary is a critical nursery and foraging area for juvenile salmonids and Dungeness crab. Commercial aquaculture and wild capture fisheries are a large part of regional economy. The various natural and cultural resource conservation designations along this coast substantiate the ecological importance of this special place. In addition, the economies of outer coast communities are strongly reliant on the abundance of natural resources to support commercial fisheries. Although the Westway and Imperium projects are not within the sanctuary, products spilled in Grays Harbor could flush from the estuary and be carried into sanctuary waters and onto adjacent shorelines. In addition, each of these projects anticipates a significant increase in petroleum product transport through Grays Harbor and along the outer Washington coast, which increases the risk for petroleum spills in open ocean areas. In this letter, OCNMS limits comments to the increased risk of petroleum product spills into estuary and marine waters, and the private and public capacity to respond effectively in the event of a spill with potential to affect the sanctuary. 1 The draft EIS outline provided with these projects’ Determination of Significance documents include two topics for analysis where OCNMS requests a strong focus - “Oil spill prevention, preparedness, response” and “Vessel Traffic”. The vast majority of shoreline habitat in the Grays Harbor estuary is characterized through the environmental sensitivity index as the shoreline type most severely impacted by an oil spill. Within Grays Harbor, highest priority should be placed on prevention, but rapid and effective containment and response capacity for a worst case spill is needed. This need is reinforced by the types of petroleum products associated with these terminal projects, Bakken crude and biofuels, which are difficult, if not impractical or impossible, to recover during spill response in estuarine or marine areas. Grays Harbor Geographic Response Plan shows the area includes water bodies with a wide range of response classifications including shallow, calm and protected water, high current, open water, and open rough water (>6’ wave height). According to the Region 10 Regional Response Team/Northwest Area Committee listing of regional spill response equipment, all the equipment available, with the exception of perhaps 2 small emergency response trailers, is owned and/or managed by one response organization, Cowlitz Clean Sweep. Response equipment in the immediate vicinity of Grays Harbor and the adjacent offshore area appears to be quite limited in both quantity and suitability for response under various conditions. Specific recommendations for this EIS scoping are: • A vessel traffic risk assessment (similar to one completed in March 2014 by George Washington University for northern Puget Sound) is recommended because of the significant increase in commercial vessel traffic anticipated with these proposals. This study and analysis of spill response capacity and needs should be completed before permits are issued for these projects. • With or without a vessel traffic risk study, the EIS should review regional changes in tanker and tug/barge traffic risk associated with these projects, including the hazardous crossing of the bar into Grays Harbor estuary and increased vessel traffic in the shipping lanes in the estuary and river. • The EIS should include analysis of the existing spill response capacity for the area and the required expansion of response capacity if each project is operational. This analysis must include both Grays Harbor and the adjacent outer coast of Washington. A professional and unbiased analysis will be required to determine if available equipment includes boom and response vessels appropriate for response in a variety of conditions and spill scenarios, including response to a spill near the estuary entrance or open marine waters. It appears that existing response capacity for the area is minimal and certainly will require significant investment to match the expanded fuel transport scenarios anticipated with these projects. • The EIS should include analysis of the response options associated with the different fuel types and probable fate of spilled materials for the full geographic scope of the projects - at the facilities, within the estuary, and along the coast outside of the estuary. • The costs to the public of modifications to the regional response capacity should be identified clearly. • The proposed U.S. Development Corp project would also increase spill risk and can be considered a reasonably foreseeable project. Therefore, this project should be included in the vessel risk and response capacity analyses. • The EIS should include analysis and description of requirements for channel dredging beyond what is currently completed for existing vessel traffic through the estuary and river. • The EIS should include modeling of spill trajectories and analyze potential impacts to coastal resources in the event of a major spill, including the potential for a spill in either estuary or open ocean areas to reach and injure sanctuary resources. We appreciate the opportunity to provide comments on these proposed projects. Sincerely, Carol Bernthal Sanctuary Superintendent A2‐2 State Agencies May 23, 2014 Imperium and Westway EISs c/o ICF International 710 Second Avenue, Suite 550 Seattle, WA 98104 To whom it may concern, We greatly appreciate the opportunity to participate in the environmental review process for the proposed Westway and Imperium expansion projects. Please consider this letter as part of the public record for the proposed bulk liquid storage facility expansions at the Port of Grays Harbor in Hoquiam. In evaluating the impact of these projects, we urge the co-lead agencies to thoroughly examine the projects’ impact to the natural environment, as well as impacts to Washington’s built environment. In light of the expansive ongoing review of the Gateway Pacific and Millennium coal export terminal projects, we feel that a similarly comprehensive review is appropriate for the expansion projects at Westway and Imperium. As with the coal export terminal projects, we are particularly interested in ensuring that this review process accurately identifies and assesses the full range of potential externalities and impacts, not just in the area immediately surrounding the project site, but statewide, in a comprehensive and cumulative fashion. Due to the gravity of the proposed projects and the widespread nature of the potential impacts, we recommend that the agencies broaden the scope of the review process to include the impacts felt by cities and counties across Washington. We also encourage the agencies to consider the cumulative impact of other large-capacity fuel export proposals in the Pacific Northwest. This letter summarizes some of the far-reaching effects of the Westway and Imperium projects that should be, at a minimum, analyzed within the scope of the environmental impact statement. I. Increased threat of oil spills By increasing the volume of oil that is transported across the state and through our waterways, the proposed expansion projects necessarily increase the risk of large-scale oil spills. The lack of tug escorts available to tankers, the lack of appropriate staffing requirements for oil barges, and the lack of appropriate emergency response planning given the proposed expansion projects are all factors that heighten the risk of a catastrophic oil spill. Additionally, the Bakken crude that is likely to be

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