Fourth 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. Commerce 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.
Enbridge’s proposed tar sands crude oil pipeline expansion has a basic contradiction that never gets addressed in the environmental impact statement. Here are excerpts from the first three paragraphs of the Executive Summary:
Enbridge Energy, Limited Partnership … has submitted applications to the Minnesota Public Utilities Commission … to construct a new 340-mile, 36-inch-diameter pipeline in northern Minnesota to replace the aging 282-mile, 34-inch Line 3 oil pipeline …
The existing Line 3 pipeline has operated for approximately 50 years. It requires extensive maintenance and is currently restricted to a capacity of 390,000 barrels of crude oil per day. Enbridge’s proposed new 36-inch-diameter pipeline would be capable of carrying up to 760,000 barrels of Canadian heavy crude oil per day, which was the original design capacity of the existing Line 3.
If Enbridge’s goal is to have a pipeline that has the same carrying capacity as the old Line 3, why does it propose using a larger pipeline? It’s no trade secret that a larger pipeline can carry more oil. So let’s look at the Enbridge Line 3 Certificate of Need Application
. On page 8-3 it says that the project’s full design capacity is 844,000 barrels a day. That’s an 11 percent increase over the 760,000 barrel a day capacity of the original Line 3.
Keep reading on that same page, and the Certificate of Need application says the “ultimate design capacity for the pipeline considering its diameter, wall thickness, steel grade, and crude slate” is an annual average of 915,000 barrels a day. That’s 20 percent more than the old Line 3.
It seems like a basic question, but the EIS does not address why there is a need for a 36-inch pipeline to maintain the capacity of the old 34-inch pipeline. Further, did the Department of Commerce consider spill analysis scenarios with the higher volume carrying capacities? If it didn’t, then the EIS is inadequate.
It seems like Enbridge is using the old sleight-of-hand, “nothing-up-the-sleeve” bumarooski. On one hand, it talks about this as an “replacement project” but in reality it is a larger pipeline with a larger capacity. Once it gets the state OK, what’s to stop Enbridge from cranking up the volume? The EIS needs to address this.
Lastly, since the final EIS came out, Minnesota Department of Commerce submitted expert testimony from its energy consultants saying there isn’t even a need to replace the capacity from the old pipeline. (See earlier blog: Minnesota Dept. of Commerce: Enbridge Has Not Established Need for the Tar Sands Pipeline; Risks Outweigh Benefits.)
There is no reason for the state to approve this pipeline, and there certainly is no reason to approve a larger pipeline.