US organizations call on Washington State to oppose Canada’s Terminal 2 expansion in the Salish Sea

41 environmental and sustainability organizations in Washington State have written Governor Inslee.

41 environmental and sustainability organizations in Washington State have written Governor Jay Inslee (PDF) asking him to oppose RBT2 on behalf of Washingtonians and the environmental, cultural and economic resources of Washington state. 

The letter identifies that the additional 468 to 520 container ship transits through the transboundary waters of the Salish Sea each year increases the risk from accidents, oil spills, vessel strikes to whales, and underwater noise impacts to endangered Southern Resident killer whales, among other things. Download the letter (PDF).

Dear Governor Inslee,

Less than a mile from Washington State, a new container ship terminal, Roberts Bank Terminal 2 (RBT2), has been proposed for construction. The environmental review for this project did not adequately address project-related impacts to Washington State’s environmental, economic, and cultural resources; public and private properties; and Tribal Treaty Rights.

RBT2 would have significant impacts. The most significant are:

  • The addition of 468 to 520 container ship transits each year through the transboundary waters of the Salish Sea, increasing accident, oil spill and vessel strike risks and underwater noise impacts to endangered Southern Resident orcas; and
  • The new terminal will cover 437 acres of critical habitat for Southern Resident orcas, salmon, and migratory birds in the Fraser River Delta.

Canada’s Federal Review Panel report states that RBT2 would have “numerous” environmental impacts, including “significant adverse effects on Chinook salmon” and “significant adverse and cumulative effects on SRKW [Southern Resident Killer Whales].”1

Since your Executive Order established the Southern Resident Orca Task Force, Washington State has made significant investments in the protection and recovery of Southern Resident orcas, their critical habitat, and their food web. RBT2 will put at risk the progress made to date on the Task Force’s recommendations and the protection and recovery of the Southern Resident orcas.

Canada’s Minister of Environment and Climate Change is expected to issue a decision in November 2020 regarding the RBT2 permit application. We respectfully ask that you oppose the RBT2 project on behalf of Washingtonians and the environmental, cultural and economic resources of this state.

If your outreach with decision-makers in Canada finds that this project is destined for approval in spite of Washington State’s strong objections, we respectfully ask that you advocate for these additional conditions to mitigate RBT2 impacts:

1. To address the increased risks of accidents, oil spills

To address the increased risks of accidents, oil spills, and cargo spills from RBT2 vessel traffic, an additional Emergency Response Towing Vessel should be required. An additional Emergency Response Towing Vessel positioned beyond the effective reach of the Neah Bay rescue tug is needed to prevent accidents and oil spills in the Salish Sea. Unlike laden oil tankers, container ships are not required to have a tug escort while transiting the Salish Sea. Container ships carry significant quantities of propulsion fuel — between 1.5 million and 4.5 million gallons.2

2. Oil spill from container ship

An oil spill similar in size or larger than the Nestucca oil spill could result from a container ship accident.

On December 22, 1988, the Nestucca barge spilled more than 230,000 gallons of fuel oil near Grays Harbor. The resulting oil slick dispersed over 800 square miles from Grays Harbor north to Vancouver Island, British Columbia, Canada, and south to Oregon. Shorelines were oiled within Grays Harbor and along 110 miles of the Washington State coast north of Grays Harbor and into the Strait of Juan de Fuca. Oil washed ashore on portions of Oregon State and Vancouver Island, British Columbia coasts. More than 13,000 oiled seabirds were collected by wildlife rescue and rehabilitation operations conducted during the spill. Estimates of actual migratory bird mortality from the spill ranged from 4 to 6 times greater than that collected.3

3. To reduce noise impacts

To reduce noise impacts from RBT2 shipping traffic that would be detrimental to the critically endangered Southern Resident orcas and other marine fauna, all container ships that call on RBT2 should be required to be accredited as quiet by a ship-classification society.

4. To reduce the environmental, cultural, and economic impacts

To reduce the environmental, cultural, and economic impacts from potential oil spills, all container ships that call on RBT2 should be required to exclusively use propulsion fuels that comply with the International Maritime Organization’s 0.50% sulfur limit. This would prohibit the use of Heavy Fuel Oil – the high viscosity, tar-like fuel that can have significant environmental and economic and cultural impacts when spilled. The required use of International Maritime Organization’s compliant low-sulfur fuel would also prevent pollution from wet scrubber discharges.

Thank you for your attention to the threats from RBT2 to Washington State’s environmental, economic, and cultural resources. As always, we welcome the opportunity to meet with you and/or your staff. For further discussion, please contact Lovel Pratt () at Friends of the San Juans. We look forward to your reply.

We greatly appreciate all your proactive efforts on behalf of Washingtonians and the natural resources of this State, especially during this difficult time.


Lovel Pratt
Marine Protection and Policy Director Friends of the San Juans

Amy Carey
Executive Director
Sound Action

Darlene Schanfald
Olympic Environmental Council

Kristen L. Boyles
Staff Attorney

David Perk
Leadership Team
350 Seattle

Marty Bishop
350 West Sound Climate Action

Shaun Hubbard
San Juan Islanders for Safe Shipping

Mike Petersen
Executive Director
The Lands Council

Paul Granquist
Team Leader
Snohomish County Beach Watchers

Jeanne Poirier Leader
350 Wenatchee

Pam Keeley
Vice President
Kitsap Environmental Coalition

Arthur (R.D.)
Grunbaum President
Friends of Grays Harbor

Ed Chadd
Olympic Climate Action

Pam Kepford Chair
350 Everett

Holly Brewer
Indivisible Bainbridge Island

Nick Manning
Climate and Health Program Manager
Washington Physicians for Social Responsibility

Kurtis Dengler
Mosquito Fleet

Jan Robinson
Chehalis River Basin Land Trust

Lin Hagedorn and Phil Ritter
Steering Committee
350 Eastside

Chris Rilling
Executive Director
Puget Soundkeeper Alliance

Dr. Kathleen S. Gobush
Northwest Director
Defenders of Wildlife

Sharon Abreu
Executive Director
Irthlingz Arts-Based Environmental Education

Howard Garrett President
Orca Network

Deborah A. Giles, PhD
Science and Research Director Wild Orca

Jayne Freudenberger
Environmental Chair
Whatcom Undaunted

Rein Attemann
Puget Sound Campaigns Manager
Washington Environmental Council

Marcie Keever
Oceans & Vessels Program Director
Friends of the Earth

Whitney Neugebauer Director
Whale Scout

Sophia Ressler
Washington Wildlife Advocate/Staff Attorney
The Center for Biological Diversity

Nora Nickum
Ocean Policy Manager
Seattle Aquarium

Daniel Villa
350 Tacoma

Arnold Martin
Vice President
Grays Harbor Audubon Society

Matt Krogh
Campaign Director

Michael Jasny
Marine Mammal Protection
Natural Resources Defense Council

Colleen Weiler
Jessica Rekos Fellow for Orca Conservation
Whale and Dolphin Conservation

LeeAnne Beres
Executive Director
Earth Ministry/Washington Interfaith Power & Light

Eleanor Hines
North Sound Baykeeper
Lead Scientist RE Sources

Rick Eggerth
Mt. Baker Group, Washington State Sierra Club

Erin Dilworth
Policy and Technical Program Manager
Citizens for a Healthy Bay

Tom Glade
Vice President Evergreen Islands

Ali Lee & Kathy Dawson
The Climate Reality Project
King County WA State Chapter

  1. Environmental assessment by Review Panel under CEAA 2012. Federal Review Panel Report for the Roberts Bank Terminal 2 Project. Page 2: and Summary of Key Findings for the Review Panel Report, Roberts Bank Terminal 2 Project: https://iaac-
  2. NOAA Office of Response and Restoration. March 8, 2016. How Much Oil Is on That Ship?
  3. U.S. Department of the Interior Natural Resource Damage Assessment and Restoration Program. Barge Nestucca Bunker Fuel Oil Spill.

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