Second in a series of critiques of the Minnesota Department of Commerce’s final environmental impact statement 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 and wild rice areas, violates treaty rights, and is unnecessary for the state’s energy security. 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.
The Line 3 environmental impact statement (EIS) is inadequate because Commerce fails to look at whether or not this project is needed, given the environmental risks it will create.
Commerce released its draft EIS in May, triggering an avalanche of public comments. Some critics questioned the need for the project, offering testimony that Minnesota’s petroleum sales are down 19 percent since their 2004 peak.
… this EIS does not assess the overall project need. Instead, the EIS evaluates the environmental impacts associated with the range of reasonable alternatives to aid the Commission’s evaluation of the need criteria set forth in Minnesota Administrative Rules.
This is a head smacker. First, Chapter 5 dedicates 646 pages to: “Existing Conditions, Impacts, and Mitigation – Certificate of Need.” I am confused about how Commerce can dedicate that much analysis to a Certificate of Need without finding it necessary to “assess the overall project need.” Most ordinary people would expect a conversation on the Certificate of Need to discuss “Need.”
Second, the EIS saw fit to include informati0n on petroleum supply but it ignored demand (that is, the need for the project). Nothing prevented Commerce from including this information. The PUC needs the information. It is relevant to the debate. Citizens have raised the issue and provided the data.
Lastly, the Introduction, page 1-5, says the EIS would help the PUC decide whether denying the Certificate of Need: “would adversely affect the future adequacy, reliability, or efficiency of energy supply to the Applicant, to the Applicant’s customers, or to the people of Minnesota and neighboring states.” Further, the PUC needs to address whether the social impacts of granting the Certificate of Need “are more favorable than the consequences of denying the certificate.”
The EIS does not include that analysis. The EIS does not consider a “No-Build”option, so the PUC has no way of comparing the difference between approving and denying the Certificate of Need.
The EIS does, however, include an analysis of Line 3’s job creation and potential property tax benefits. If Commerce wants to take an expansive definition of environmental impacts to include jobs and tax implications, surely it could include an analysis of project need.
Being selective in the facts it chooses to present is a form of bias.