Vancouver Energy submitted its official comment letter to the Energy Facility Site Evaluation Council (EFSEC) January 22, 2016. We value the thorough and transparent review process and the opportunity to comment on the facts and analysis in the Draft Environmental Impact Statement (DEIS). We are working to address comments and perspectives by aligning with the proper institutions or organizations to ensure we construct and operate the terminal in a way that is safe, environmentally responsible and beneficial to our community and Washington state as a whole.
Key Highlights, which are incorporated in our DEIS comment letter:
- We concur with an important general conclusion of the DEIS that the facility under normal operations is designed and can be mitigated to have no probable significant adverse impacts.
- The DEIS also indicates that a comprehensive review found no reasonable alternatives to the project, that the current demand for crude oil will continue, and that no significant cumulative impacts could be found for the facility in relation to past, present and reasonably foreseeable future actions.
- It’s important to reiterate that, even with all the good work that went into this document, there are some areas where we have very substantial concerns.
- The State Environmental Policy ACT (SEPA), which governs the preparation and content of Environmental Impact Statements in Washington, has a very specific definition of what constitutes a “significant” impact. Portions of the DEIS are inconsistent with this SEPA definition.
- Another area of major concern is that the DEIS fails to recognize mitigation measures that have been proposed by Vancouver Energy or are designed into the facility, which SEPA requires be included.
- With appropriate consideration of our comments and corrections and other input it receives, EFSEC can create a Final EIS that will be an accurate and valuable assessment of the project.