This project is in the scoping phase. That means the Department of Ecology is asking the public what needs to be included in the scope of the environmental impact study.
Five hundred people turned out in Vancouver to testify at the hearings, but we need to send our comments electronically.
Tell the agencies what they need to include. Tell them how the oil trains would affect the people and places you love. Don’t assume that they have read the newspaper.
The deadline for public comment is November 5.
Below is a long list of possible comments. Please add some of them to your comment, and then come back and choose some more.
Send your comments to: comment@shellraileis.com
Here is some sample language:
To Washington Department of Ecology and Skagit County
I'm writing because I am deeply concerned about Shell’s proposed crude-by-rail project in Anacortes.
I urge you to include all of the following in your Environmental Impact Assessment of the Shell Anacortes Crude by Rail facility.
An analysis of the impacts of an oil train explosion on all rail communities.
An analysis of a derailment spill on all rail communities.
A report of how many tanker trains (LPG, alcohol and oil) have derailed and ruptured since 2012. How many caught fire, and how many resulted in explosions.
Include a report of the crashworthiness of the Old and the NEW tank cars. At what speeds they could puncture? See: www.bloomberg.com/news/articles/2015-03-13/speed-limits-may-not-stop-fiery-oil-spills-u-s-rail-chief-says
www.thompsonhine.com/publications/dot-proposes-new-tank-car-standards-classification-rules-operational-controls-for-crude-oil-ethanol-transportationInclude a discussion of what makes crude oil more dangerous than motor oil.
Compare the vapor pressure for Bakken Crude with the vapor pressure in the Quebec explosion.
Explain the progression from a spill to a fire to an explosion.
Explain why two trains carrying tar sands crude caught fire and exploded in Ontario in the winter of 2015.
Include an actuarial forecast of the number of non-yard rail accidents that the project could be expected to generate over the next thirty years. Include the round trip, because empty cars are also explosive. Google “Derailment Statistics”.
Include an actuarial forecast of the number of non-yard derailments that the project could be expected to generate over the next 30 years.
Include a thorough health impact assessment, including noise, emissions, blocked emergency response, burns, and loss of life.
Include the impacts of oil trains on other rail and vessel traffic.
Include the greater loss of property values from oil train traffic as compared with other rail traffic.
Include the impacts to our economic well-being, including fishing, tourism and vessel traffic in the event the Columbia River is shut down by a spill. Include the jobs that will be lost in the renewables sector. Your Economic Impact Analysis Planning model needs to include the additional real and perceived risks associated with oil train fires and explosions.
Include the fugitive greenhouse gas emissions from the oil fields, from the trucks and gathering area, from the tank cars during transport and unloading. Recent reports indicate that fugitive methane emissions are much higher than previously thought, that the Bakken Well Operators flare much more methane than the national average, and the industry loses between .5% and 3% of the load from wellhead to refinery.
Include the greenhouse gas emissions produced by the locomotives, the refinery, and by the end user.
Include the potential impacts to the waterways, wetlands, and aquifers along the transportation route and surrounding the refinery, and to the animals that depend on them. Include the sole source aquifers for the drinking water in Vancouver and Spokane.
Include an assessment of fire department and emergency service preparedness in the event of an oil train fire. Include the cost of getting prepared and staffed, and the source of funding.
Include how different feedstocks have different risks and spill response needs.
Include an assessment of the adequacy of insurance for a worst-case oil train fire and explosion. According to a leading insurance expert "...there is not enough available coverage in the commercial insurance market anywhere in the world to cover the worst-case oil train derailment scenario . . . "
Include the cumulative impact of all the existing and proposed crude-by-rail facilities, coal proposals, and oil transport in the Pacific Northwest and how the Shell Refinery proposal adds to this impact.
Provide an assessment of the causes of oil train derailments, including how the extra weight exposes weaknesses. The failure of equipment used to inspect tracks, and broken axels.
Include how well a shoreline-spill during a storm or a river spill at flood stage could be cleaned, and what would be the cost. Think Dilbit Disaster on the Kalamazoo, $1.2 billion.
What assurances do we have that production elsewhere will decrease to compensate for our extra output?
Include the potential of a mudflow from Mt. St. Helens which could erupt at any time, and the two worst landslide areas in America, which are located in the Columbia Gorge and between Seattle and Everett.
Determine if inspectors use infrared cameras to detect vapor leaks from the tank cars. They should.
Include a component on crew size, worker fatigue, human error, and the lessons learned in the recent whistleblower judgement against BNSF.
Include the impact of increased supply on market interest in electric cars or hybrids.
Asses the relative degree of risk and benefit to the state of Washington.
Thank you for considering these comments.
Include your name, city, and email address. Ask the agencies to include your comments in the record and notify you of action taken.
Don’t forget to vote.
Don and Alona Steinke