Keeping the pressure on PUC, Enbridge to address Line 3’s human trafficking risks

On Wednesday, Sept. 12, Healing Minnesota Stories ran a post critical of the Minnesota Public Utilities Commission (PUC) for approving the Enbridge Line 3 pipeline with lax oversight and accountability for the human trafficking risks the massive construction project poses. The post identified problems with how Enbridge was moving forward with its required Human Trafficking Prevention Plan.

Now, three weeks after that post, calls and emails have provided some updates, but suggest no follow up has happened.

A participant in the Greater Than Fear Rally & March in Rochester Minnesota, 2018. Photo by Laurie Shaull.

Enbridge Line 3 is a proposed multi-billion dollar crude oil pipeline project that would run 340 miles through northern Minnesota. Public testimony and the state’s Line 3’s environmental impact statement raised concerns about the connection between the large influx of out-of-state construction workers for the project and increases in drug and sex trafficking along the construction route. The risk is particularly high for vulnerable Native American women and girls.

Due to such concerns, the PUC required Enbridge to develop a Human Trafficking Prevention Plan as a condition for its Line 3 Route Permit. Yet the PUC gave Enbridge primary responsibility for the plan knowing that Enbridge denied any connection between pipeline construction and human trafficking.

As reported earlier, Enbridge has completed its Human Trafficking Prevention Plan but won’t release it, delaying public scrutiny.

The good news is that a Minnesota Court of Appeals ruling has put Line 3 back before the PUC. The PUC needs to fix Line 3’s Environmental Impact Statement and re-vote on Line 3’s permits. This gives advocates the opportunity to push for stronger language and public engagement around human trafficking prevention.

Here are the updates:


Enbridge received a link to the Sept. 12 blog. They have not challenged its content or responded at all.

Minnesota Statewide Human Trafficking Task Force:

As reported earlier, the PUC’s Route Permit required Enbridge to coordinate work on Line 3’s Human Trafficking Prevention Plan with several key parties. That list included the Minnesota Statewide Human Trafficking Task Force.

Beatriz Menanteau, a supervisor at the Minnesota Department of Health, oversees the Human Trafficking Task Force. In a Sept. 30 email, she wrote:

At this time, the Minnesota Department of Health (MDH) staff who coordinate the Minnesota Human Trafficking Task Force … have not yet received communication from Enbridge Inc. regarding the development of a Human Trafficking Prevention Plan. MDH remains committed to preventing human trafficking throughout Minnesota. In our role as facilitator of the [Minnesota Human Trafficking Task Force,] we are prepared to engage in those efforts when contacted.

Comment: Enbridge was put on notice in the Sept. 12 blog that the Minnesota Human Trafficking Task Force had been kept out of the loop. Three weeks later, still no outreach by Enbridge.

The Minnesota Department of Health now knows that Enbridge has finished its Human Trafficking Prevention Plan without consulting its Human Trafficking Task Force. It should not passively wait for Enbridge to call; that’s clearly not happening. If it is committed to preventing human trafficking throughout Minnesota, it should be leaning on the PUC and Enbridge to start the process over and do it right.

Red Lake Tribal Attorney:

The PUC’s Line 3 Route Permit also required Enbridge to coordinate the Human Trafficking Prevention Plan with “all Minnesota Tribes that wish to participate.”

Attorney Joe Plumer represented the Red Lake Nation before the PUC on the Line 3 case. He said no one from Enbridge had contacted him about the Human Trafficking Prevention Plan.

I checked with the director of the women’s shelter here in Red Lake who would be the most likely person to deal with issues like this. She hasn’t had any contact from anybody from Enbridge.

Plumer added that Red Lake has a couple of law enforcement officers dedicated to human trafficking. They are involved in the Tribes United Against Sex Trafficking (TRUST) Task Force.

Comment: The TRUST Task Force is led by the Fond du Lac Band of Lake Superior Chippewa. It has  representation from eight of Minnesota’s 11 tribes. As reported earlier, Fond du Lac Investigator and TRUST Task Force Commander Kelly Haffield declined to comment on Enbrdge’s Human Trafficking Prevention Plan, saying she was not authorized to speak.

If Enbridge’s attempt to coordinate with “all Minnesota Tribes that wish to participate” boils down to working with the TRUST Task Force, it’s missing important community voices.

Further, making the TRUST Task Force a main contributor to the Human Trafficking Prevention Plan puts the Fond du Lac Band in a difficult spot.

Fond du Lac had strongly opposed Line 3. However, the PUC forced it into a no-win situation on route options. Fond du Lac was given the choice between keeping the new Line 3 in the existing trench that runs through the reservation, or open a new route that would just skirt the reservation. The new trench  would do more environmental damage and still pose spill risks.

Ultimately, Fond du Lac agreed to renew Enbridge’s lease across reservation lands. As part of the deal, Fond du Lac “agreed not to participate in any opposition to the project,” MPR wrote. While the agreement allowed the band to comment on cultural and other issues, that’s a gray area. If the TRUST Task Force, led by Fond du Lac, criticizes Enbridge for a lax Human Trafficking Prevention Plan, would that invalidate the Band’s agreement?

Minnesota Bureau of Criminal Apprehension:

Healing Minnesota Stories asked Enbridge about the company’s failure to engage the Minnesota Human Trafficking Task Force. Enbridge said it was working with the “Minnesota Human Trafficking Investigators Task Force” led by the Bureau of Criminal Apprehension (BCA).

Comment: First, the Line 3 Route Permit required Enbridge to work with the Minnesota Human Trafficking Task Force, not the Human Trafficking Investigators Task Force. (It seems clear that Enbridge would rather work with law enforcement than service providers on human trafficking issues.)

Second, Healing Minnesota Stories has been trying for more than three weeks to get a comment from the BCA regarding its role in developing Enbridge’s Human Trafficking Prevention Plan. Answers have been promised but not forthcoming. If and when the BCA responds, we’ll update this post.

Breaking Free:

A chance meeting with Lori Paul, the communications and development specialist for Breaking Free, provided more information about Enbridge’s Human Trafficking Prevention Plan than the BCA has.

Breaking Free is committed to ending all forms of sex trafficking and prostitution. Its offerings include a restorative justice program for men caught purchasing sex. Someone from the BCA reached out to Breaking Free to ask if one of their men could be interviewed for a film, Paul said. They also filmed a Breaking Free employee whose daughter went missing and then was found.

“The film, I’m being told, is being made for Enbridge,” Paul said.

Paul rejected Enbridge’s claim that Line 3 construction would not increase human trafficking.

“Traffickers know where the demand is,” Paul said. “They will drive their women to those locations. It becomes part of a circuit.”

She described one circuit as Chicago to Minneapolis to North Dakota to Las Vegas: “That definitely was a circuit our women here in Minnesota say that they have been taken to.”

For perspective, approximately 8,000-12,000 people are prostituted daily in Minnesota, Paul said.


Dan Wolf, the PUC’s executive secretary, received a copy of the initial blog. In a later email exchange, he was asked if he had looked into the questions/problems the blog raised. Here is his response.

As you know, the Minnesota Court of Appeals determined that the Final Environmental Impact Statement for the Line 3 Project was inadequate; and the Minnesota Supreme Court declined to review that opinion. Therefore the Pipeline Route Permit is not in effect.  As such, the Commission does not have jurisdiction to take action on any of the Permit conditions

Comment: Wolf didn’t answer the question. It’s disappointing he didn’t choose to proactively engage Enbridge on this issue. Just because the permit is now in limbo doesn’t mean the PUC can’t ask Enbridge tough questions. If the PUC does amend the Line 3 environmental impact statement and reapprove the Line 3 Route Permit, human trafficking still will be a live issue.

If and when the Route Permit comes up again, the conditions around preventing human trafficking will need to be strengthened. It’s best to get ahead of the problem now instead of waiting until the last minute.

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