Jan. 2019. Comments by ALERT and others on EIS scoping for proposed 2019 Beaufort Sea Lease Sale focused on federal government’s fiduciary duty to protect the ocean and other public trust resources under Public Trust Doctrine. “We find the duties of government trustees under the PTD must be considered in the EIS [scoping process]…"
Citizens use ALERT template to request real change after Enbridge tar sands oil spill disaster
Aug 2016. Shortly after EPA closed comments for the BP Whiting refinery settlement (see below), an opportunity arose to replicate our model for oil spill settlements. EPA opened comments on the much larger 2010 Enbridge tar sands oil disaster in the Kalamazoo River and area. The same multi-state mid-west coalition managed to craft technical comments entirely by themselves. The coalition doubled-down on the same requests as the BP Whiting Refinery, plus they requested that an additional third tier of spill prevention and response for the upper Mississippi River.
Download the support exhibits (zip file with 11 documents)
Letter to EPA requesting action on Canadian rulemaking
Sept. 2015. Request to U.S. EPA to take proactive measures to prevent Canada from approving the same toxic Corexit dispersants in oil spill response that ALERT and other concerned citizens are seeking to ban in the U.S.
Aug. 2015. Technical comments by ALERT and others on Environment Canada rulemaking, requesting that screening protocols and environmental monitoring requirements be established, based on best available science and weight of evidence from past spills, prior to listing any spill treating agents or products for use in oil spill response.
June 2014. Supplement to our original petition to EPA for NCP rulemaking, requesting among other things: a comprehensive update to address response measures for tar sands (non-buoyant) oil and fracking (explosive) oil; citizen advisory councils for area response plans; and provisions for protecting public health and worker safety – instead of only wildlife rescue and rehabilitation. Issues raised in our petition creates grounds for future legal action.
Science of human health harms from oil spill & dispersant exposures
Dec. 2018. Expert comments by Riki Ott, PhD, on behalf of Canadian ally-intervenors opposing Trans Mountain Pipeline Expansion Project. Summarizes studies from May 2015 to Dec. 2018, including finding from BP Deepwater Horizon studies. Follows May 2015 expert comments on the evolution of scientific understanding of human health harms from oil exposures.
Citizens request real change after BP Whiting oil disaster
July 2016. ALERT responded to a call from a multi-state coalition in Illinois, Indiana, Michigan, Wisconsin, and Minnesota, asking for technical assistance with comments to the EPA regarding the 2014 BP Whiting refinery oil spill into Lake Michigan (see blog post). We developed a model for future spill settlements, requesting maximum fines and a condition to fund a third tier of spill prevention and response for Lake Michigan involving local government and concerned citizens. These conditions are modeled after the Regional Citizens’ Advisory Councils and environmental monitoring that were required under the Oil Pollution Act of 1990 and that currently exist in Prince William Sound, Alaska, post Exxon Valdez oil spill.
Sept. 2015. Union of British Columbia Municipalities acknowledge vital role that local emergency responders play in emergency preparedness and response for local oil and chemical spills, and call for provincial and federal governments to adequately fund and integrate local plans into regional response plans and to compensate local governments for response measures. Model for other communities seeking to engage in oil spill preparedness and response planning.
April 2015. ALERT technical comments on EPA rulemaking, to request more decision-making authority for local governments, citizens and Tribes; banning use of products with toxic and/or proprietary ingredients; closing loopholes that negate the planning process; more stringent screening protocols and environmental monitoring requirements before and after product use; a public process for removing products that don’t work as intended; and clarification of definitions, based on current science, among other things.
Nov. 2012. Comments by ALERT and others to EPA for a formal rulemaking to revise the National Contingency Plan’s policies regarding dispersant use. Our petition uses latest science to justify our demand to ban toxic dispersants and other chemicals in oil spill response. Protocol requires a two-year wait before further legal action.