December 13 1998
Floyd Rogalski
USDA Forest Service
Wenatchee National Forest

Mr. Rogalski;
Washington Environmental Council believes the environmental impacts of the extraction, processing, distribution, and consumption of petroleum products are significant, and that they are a major threat to our state's natural heritage and the health of its citizens and communities.

We are submitting comments on two issues of concern:
1) The proposed cross Cascades pipeline DEIS, and
2) The direction of flow of the Chevron pipeline.

1) the cross Cascades pipeline DEIS:

As proposed, the cross Cascades pipeline would have the capacity to carry up to 4.4 million gallons of gasoline, diesel and jet fuel each day through 227 miles of pipeline. This pipeline would traverse threatened and endangered species habitat including 167 streams, 16 acres of wetlands, and Mount Baker and Wenatchee National Forests. This pipeline would traverse the Cle Elum, Yakima, and Columbia Rivers. It would pass near the Alpine Lakes Wilderness area, Tinkham Campground, McClellan Butte Trail and Olallie State Parks, Annette Lake Trail, the Surveyor Lake area and the Pacific Crest National Scenic Trail, and four (4) wildlife refuges. The project would actually run through John Wayne Trail/Iron Horse, Ginko, and Twin Falls State Park.

In spite of advanced state of the art pipeline technology claimed by OPLC, numerous pipeline spills and leaks have occurred at various locations in the past, and could reasonably be expected to continue to occur in the future. The uncertain relationship between degree of technology and pipeline safety may be demonstrated by noting that the Olympic Pipeline Company has criticized the Yellowstone Pipeline as being unsafe, despite the fact that the Yellowstone pipeline has more built in safety features than does the proposed cross Cascade pipeline. Further, although the number of spills from pipelines may be low relative to other sources, the actual damage done may be much greater, given that pipelines frequently leak for long periods of time before being discovered, relative to other sources.

According to current studies, existing pipelines can easily meet the projected needs of petroleum products in Eastern Washington. Specifically, these needs can be met by two existing pipelines which move petroleum products into Washington state: the Yellowstone Pipeline and the Chevron Pipeline. The Yellowstone Pipeline, with a capacity of 56000 BPD runs from Billings, Montana to Spokane, Washington. The Chevron Pipeline, with a capacity of 18000 BPD, runs from Salt Lake City, Utah through Boise, Idaho to Pasco, Washington.

With the current pipeline configuration in place, the cross Cascades pipeline is unnecessary. According to the National Environmental Policy Act (NEPA), alternatives such as the existing Eastern Washington pipeline system must be considered in an EIS. We are concerned that alternatives dictated by environmental law were not addressed in the formulation of the current DEIS.

Consumption of total refined products in Eastern Washington is projected at 68,000 BPD in 2000. The Yellowstone Pipeline supplies the bulk of that demand. On the other hand, the capacity of the proposed cross Cascades pipeline could be increased to 110,000 BPD. Because this capacity dwarfs any possible Eastern Washington product deficit caused by a possible loss of the Cheveron Pipeline, we are concerned that a large ecologically damaging project may be undertaken for little net use, or alternatively that the excess capacity will encourage future pipeline activity to out of state destinations. Neither of these possibilities is environmentally acceptable.

Aside from the question of environmental risk, we believe that such a large expansion of oil industry infrastructure as the cross Cascades pipeline would decrease incentives for energy conservation, and delay efforts toward switching to cleaner alternative fuels. Such factors should be addressed in the DEIS.

2) Direction of flow of the Chevron Pipeline:

We are very concerned with reports that Chevron plans to reverse the flow of petroleum products in its Salt Lake City to Pasco pipeline. This action would carry petroleum products from Pasco to Boise and Salt Lake City.

Such increased eastern movement of petroleum products may increase barging of products up the Columbia River to Pasco, as well as increase the demand for a cross Cascades pipeline by eliminating the 18,000 BPD Chevron contribution to the product supply of Eastern Washington. On the other hand, such barging would immediately invalidate the primary argument made in the cross Cascades pipeline DEIS, which was predicated on the concept that the cross Cascades pipeline would reduce barging.

Conclusion [Applies to 1) and 2)]:

Chevron pipeline flow reversal, as well as cross Cascades product movement would very likely increase oil tanker movement in Puget Sound and the Strait of Juan De Fuca.

For all of the above reasons, it is clear that Washington state would incur an unacceptable increase in environmental risk for no Washington State gain, were either the Chevron Pipeline flow to be reversed or were the cross Cascades pipeline to be constructed. Such risk can only be addressed by a valid EIS which considers reasonable alternatives. Washington Environmental Council opposes both the cross Cascades pipeline, and flow reversal of the Chevron pipeline, and believes the current pipeline system, or "Eastern Pipelines Alternative" is the best means to supply Eastern Washington with its predicted supply of petroleum products.

A Cheveron Pipeline DEIS must be written and the cross Cascades pipeline DEIS must be rewritten before the Chevron Pipeline flow may be reversed. If the Chevron Pipeline flow is not reversed, the cross Cascades pipeline is not needed and should not be built.

Sincerely,

Rodger Herbst
Chair,
Pollution and Health Committee
Washington Environmental Council Seattle WA 98104

CC:
David Mann
President,
Washington Environmental Council