Commerce Takes Enbridge Assumption as Fact, Low Balls Impact of New Tar Sands Pipeline

First in a series of critiques of the Minnesota Department of Commerce’s final environmental impact statement (EIS) on Enbridge Line 3, a proposal to expand and reroute a tar sands crude oil pipeline through northern Minnesota. This project threatens the Mississippi River, wild rice areas, and Anishinaabe treaty rights. The Minnesota Public Utilities Commission is taking public comments on the adequacy of the EIS until 4:30 p.m. Oct. 2. To learn how to submit comments, click here.

Today, let’s critique the debate over the useful lifespan of a new crude oil pipeline. The EIS assumed the new Line 3 would only last 30 years. Anyway, Enbridge told the Department of Commerce it would operate for 30 years and Commerce did not challenge the assumption, even though current pipelines have lasted much longer.

Commerce had the lead role in writing the EIS on Enbridge Line 3 and its goal was to be a neutral arbiter of the facts. As it states in Appendix T (page T-i): “an EIS does not advocate, recommend, or state a preference for a specific alternative. Instead, it analyzes and compares alternatives so that citizens, agencies, and governments can work from a common set of facts.”

This is one example where Commerce — by accepting Enbridge’s assumption and ignoring public criticism — is showing bias favoring the pipeline. This is one reason the final EIS is inadequate and needs to be redone.

Commerce summarized public criticism, and responds to it, in Appendix T.

Additionally, a number of commenters cited the presence of the existing Line 3, which has been in operation for well over the 30-year timeframe analyzed in the EIS, as evidence that the EIS should have analyzed a 50-or 60-year operational timeline. The Applicant has stated that the expected lifetime of the proposed project is approximately 30 years. Due to the difficulty of predicting future events or energy needs, and considering the dynamic nature of energy markets and the finite nature of oil deposits, the Department did not think it was warranted to include alternative operational timelines. (pages T-1 to T-2)

It costs Enbridge nothing to estimate a short lifespan. There is nothing binding that would make Enbridge shut down the pipeline in 30 years. Assuming a 30-year lifespan has the advantage of low balling the project’s environmental impacts.

For instance, the EIS estimates that the social cost of carbon pollution from the pipeline would be $287 billion over 30 years. The social cost of carbon “is meant to be a comprehensive estimate of climate change damages. It includes changes in net agricultural productivity; human health; property damages from increased flood risk; and changes in energy system costs, such as reduced costs for heating and increased costs for air conditioning.” (page 5-447)

It needs to be emphasized that these are all costs that Enbridge is shifting onto other parties, including you and me. The estimate of the social costs of carbon would be much higher if Commerce would have considered a longer lifespan as a possibility.

According to Enbridge’s website: the Line 3 Replacement is the largest project in company history. The Canadian section will cost $5.3 billion in Canadian dollars and the U.S. section will cost $2.9 billion. With that investment, will Enbridge shut things down after 30 years?

Due to the “difficulty of predicting future events or energy needs” Commerce took the easy road and accepted Enbridge’s assumption as fact and did not offer other modeling based on reasonable criticism.