Action 116. Ask Skagit County not to fast-track a proposed oil-by-rail expansion

Skagit County has received a proposal from Shell Oil to bring oil by rail to their refinery by the construction of a new spur from the mainline BNSF railroad. About a mile of new track, a new electrical substation, and new platforms would be included in order to facilitate the direct connection of railcars bringing oil primarily from the Bakken oil shale in North Dakota. Shell estimates that this expansion will facilitate the addition of more than 600 fully loaded oil cars a week to their Puget Sound Refinery (PSR) located in Anacortes.

The PSR is already a substantial receiver and processor of petroleum products. Historically (the refinery has been around since the 1950s), most of this product came from Canada via pipeline. Currently, most of their product comes via tanker from oilfields on Alaska’s North Slope. The PSR currently processes up to 145,000 barrels, or 5.7 million gallons, of crude oil per day – according to Shell, “enough to fill a 17-foot-deep swimming pool the size of a football field.” I think I need to pause a moment and process that fact.

OK, so let’s process that fact. The direct-from-rail expansion is proposing to add 600 tankers a week. If we assume they are using something like DOT-111 rail cars, a common (and unfortunately commonly known to have poor crash resistance) oil tanker that maxes out at around 35,000 gallons, that’s about 21 million gallons of oil that Shell is expecting to move through this new rail spur each week, or over a 5-day work week, about 4 million gallons a day. So, if the refinery is currently processing up to 5.7 millions of gallons per day, the oil-by-rail represents a significant (like another 75% of current amounts processed) increase in petroleum product reaching this refinery. That will bring the new total processing in the ballpark of 8 to 10 million gallons a day. If we convert back to barrels, we’re in the range of up to a quarter of a million barrels of oil processed per day at the PSR. 

The Anacortes oil-by-rail expansion is only one of several proposed expansions that could, overall, increase the amount of oil being moved around by rail in Washington State to about 800,000 barrels per day. By recent estimates the world consumes around 90 million barrels of oil a day.The amount of oil-by-rail that’s proposed to be moved around Washington, therefore, could add up to nearly one percent of the world’s daily oil consumption. That seems pretty incredible to me, that we could have 1% of the entire world consumption of oil moving around railways in one state in one country. And given our recent track record on safety of oil-by-rail (see Action 97), I think Washingtonians have got more than a little reason to get nervous about the safety aspects of a substantial increase in rail traffic, along with our contributions to greenhouse gas emissions. In the case of the PSR, we’re also talking about expanding rail capacity and tanker transport within a few hundred feet of the Padilla Bay National Estuarine Research Reserve. In reading the environmental documents that have been submitted in support of this expansion, there is no mention I could find of any concerns that might reasonably be associated with substantive increases in tanker traffic directly across the mouth of Padilla Bay.


Location of the proposed spur rail expansion at the Shell PSR. Source:


The proposed project also has substantive impacts on wetlands. The spur expansion will also permanently alter 7 of the 21 remaining wetlands, for a total of 25 acres of wetland destruction, on the peninsula property on which the PSR is located, mitigated by the purchase of off-site mitigation bank credits. Without going too far down the regulatory rabbit hole that is wetland mitigation, I will say that the proposed mitigation ratio is surprisingly low considering we are trading extant functioning estuarine wetlands for constructed/enhanced wetlands in a freshwater riparian bank, and the storm water treatment approach is surprisingly unoriginal (let’s excavate wetlands and put in detention ponds to treat storm water, rather than enhancing existent wetland function???). 

The most frustrating aspect of this entire proposal, however, is not the PSR spur rail expansion itself and the incremental addition of increased emissions, safety risks, and wetland destruction.  I do believe given the scale of the proposal it is inappropriate for Skagit County to green light this proposal without a full environmental review, and I have said so in public comment on the matter. However, the true crux of the problem here is that we have no way to comprehensively assess these incremental movements towards oil-by-rail expansion. While we can oppose each of these proposed expansions, there is no government or leadership entity that is recognizing and accounting for the cumulative impacts of a movement towards 800,000 barrels of oil per day moving around our rail system. As that economic engine grows in a small, piecemeal way, its overall impacts- on the climate, on creating an infrastructure and an economic engine that will be increasingly difficult to ignore or transition from towards more sustainable forms of energy- will be more and more difficult to overcome. Meanwhile, Governor Inslee just signed an executive order establishing goals for Washington to cut its greenhouse gas emissions, while maintaining a resounding silence on the fact that Washington is daily growing its capacity to transport, process and export carbon to Asia and other fossil-fuel hungry areas of the world. That approach is the political equivalent, in my opinion, of sticking one’s finger in the dike while the reservoir is overtopping.  So, in the absence of of a federal or state framework in which we can transparently evaluate the cumulative impacts of the growth of oil-by-rail, here we must be, fighting each fight with the true scope of this issue on our minds. 



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