Environmental Impact Statement for Rule to Expand Tug Escort Requirements in Puget Sound

The Washington State Department of Ecology approached ERG requesting support with preparing an Environmental Impact Statement (EIS) pursuant to the Washington State Environmental Policy Act. The EIS would evaluate the environmental impacts of a proposed rule that would change escort tug requirements for small and medium-sized oil tankers and barges in Puget Sound. The rule would therefore change the location and intensity of escort tug activity and the risk of oil spills. Ecology required assistance with conducting technical analyses and authoring substantial portions of the EIS to meet a statutory deadline for finalizing the rule.

ERG quickly assembled a team of internal National Environmental Policy Act (NEPA) practitioners and subject matter experts and enlisted specialized subcontractors to conduct intensive technical analyses for the EIS. ERG led the analyses and content development regarding potential impacts to water quality, air quality, plants and animals, underwater and airborne noise, Tribal resources, and environmental justice. Our team developed and implemented the methodology for each analysis, including underwater noise modeling to assess impacts on marine mammals and dispersion modeling to assess air quality impacts in shoreline communities. We conducted the research and analyses on an accelerated schedule to allow Ecology to provide informative updates during public workshops. Our team contributed more than 500 pages of EIS content, discipline reports, and technical memoranda within less than seven months of finalizing the methodology. With ERG’s support, Ecology successfully reached the target deadline of publishing the proposed rulemaking and Draft EIS in June 2025. Following the public comment period, ERG will support Ecology with addressing public comments and finalizing the EIS.