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.
Marine Protection and Policy Director Friends of the San Juans
Olympic Environmental Council
Kristen L. Boyles
350 West Sound Climate Action
San Juan Islanders for Safe Shipping
The Lands Council
Snohomish County Beach Watchers
Jeanne Poirier Leader
Kitsap Environmental Coalition
Friends of Grays Harbor
Olympic Climate Action
Pam Kepford Chair
Indivisible Bainbridge Island
Climate and Health Program Manager
Washington Physicians for Social Responsibility
Chehalis River Basin Land Trust
Lin Hagedorn and Phil Ritter
Puget Soundkeeper Alliance
Dr. Kathleen S. Gobush
Defenders of Wildlife
Irthlingz Arts-Based Environmental Education
Howard Garrett President
Deborah A. Giles, PhD
Science and Research Director Wild Orca
Puget Sound Campaigns Manager
Washington Environmental Council
Oceans & Vessels Program Director
Friends of the Earth
Whitney Neugebauer Director
Washington Wildlife Advocate/Staff Attorney
The Center for Biological Diversity
Ocean Policy Manager
Grays Harbor Audubon Society
Marine Mammal Protection
Natural Resources Defense Council
Jessica Rekos Fellow for Orca Conservation
Whale and Dolphin Conservation
Earth Ministry/Washington Interfaith Power & Light
North Sound Baykeeper
Lead Scientist RE Sources
Mt. Baker Group, Washington State Sierra Club
Policy and Technical Program Manager
Citizens for a Healthy Bay
Vice President Evergreen Islands
Ali Lee & Kathy Dawson
The Climate Reality Project
King County WA State Chapter
- Environmental assessment by Review Panel under CEAA 2012. Federal Review Panel Report for the Roberts Bank Terminal 2 Project. Page 2: https://iaac-aeic.gc.ca/050/documents/p80054/134506E.pdf and Summary of Key Findings for the Review Panel Report, Roberts Bank Terminal 2 Project: https://iaac- aeic.gc.ca/050/documents/p80054/134507E.pdf ↩
- NOAA Office of Response and Restoration. March 8, 2016. How Much Oil Is on That Ship? https://response.restoration.noaa.gov/about/media/how-much-oil-ship.html ↩
- U.S. Department of the Interior Natural Resource Damage Assessment and Restoration Program. Barge Nestucca Bunker Fuel Oil Spill. https://www.cerc.usgs.gov/orda_docs/CaseDetails?ID=961 ↩