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So I took time to read some of the Draft Environmental Impact Statement for the Line 3 “Replacement” Proposal that is currently open for public comment. [Through July 10th, if you want to add your commentary.]  I think anyone in the middle U.S. should be submitting comment as the Mississippi Watershed is pretty large.  If we fuck it up here near the headwaters, the rest of you are screwed.   You can read it here: https://mn.gov/commerce/energyfacilities/resource.html?Id=34695 (see below on how to submit your comments).

I was offended that the DEIS sounded in large part like a very cheery presentation from the conscientious, safety focused, public utility giant… Enbridge.  Yes, there were statements and commentary from various groups that appeared to be concerned more with Mother Earth than the profits of a large corporation.  But these were in the Appendices.  It appears that Enbridge’s account has been taken at face value and presented as fact with the most likely plan being implementing this pipeline.  There does not appear to be much consideration for telling Enbridge to simply go through Canada and leave Minnesota alone.

In addition, when I asked Department of Commerce representative Jamie MacAlister whether Tribal Resources were being given priority consideration in the matter, I was assured they were NOT.  WHAT?!?  The right of people to live by their ways with regard to their food, water and spirituality took no bigger place in the decision than a company’s desire to make some money?  It does not seem to me that the needs of the citizens of Minnesota (and anyone downstream of us) are being given due consideration.

There is an ability to see where Enbridge concerns lie if you look at this passage (Appendix P, Volume 1, page 253). Enbridge Comment 1The main concerns are with infrastructure and inconvenience, not less dense human populations, food foraging environments, or birthing grounds of our migratory birds.  In fact, they are more concerned about “crude oil flooding the highway, causing accidents” than how that crude oil flooding might affect the way of life for those of us who rely on wild rice and fresh fish as part of our diets.

While Enbridge calls this a Line 3 Replacement, it’s in actuality a Dumping of the old Line 3 and an Addition of a new, bigger Line 3 through a new corridor.  Did you know that while you can’t leave a fuel tank buried in the ground long-term, we currently have no policy requiring the removal of an oil pipeline once it is no longer actively used?  Why would we NOT require this dirty infrastructure be removed rather than leaving it for the next generation to clean up?  Enbridge again seems pretty concerned with infrastructure issues rather than clean water or wildlife and human impacts.  (Appendix B, pg 14)

Removal EnbridgeEnbridge assures us that, if abandoned, the old line will be purged and cleaned.  If it’s done in any way similarly to the “clean-up” done in Kalamazoo, reason would predict low expectations of a thorough job. The inadequate work done by Enbridge to clean up oil spills should be considered when evaluating their proposed methodology for cleaning up their abandoned pipeline.   Their integrity leaves much to be desired, so much so that to work with this corporation should be seen as illogical and foolish.

When you consider Enbridge’s track record, it is just a matter of time before Minnesota has to deal with ANOTHER spill.  We (Minnesota AND Enbridge) already hold the record for the largest inland spill in US History.  http://www.grandrapidsmn.com/opinion/happy-anniversary-the-largest-inland-oil-spill-in-u-s/article_2ade2706-004f-11e7-9023-2b31a01741a6.html  Now Enbridge is looking at running pipeline that carries substances they can’t even reveal the nature of to us in the public.  In addition, they want to run it in places where no pipeline has gone before, including many wetlands, creeks, and large rivers.  I’m hopeful the powers that be in Minnesota come to their senses and refuse to allow this to happen.

Enbridge reports in the DEIS that they have all kinds of safety programs in place to prevent “accidental releases”, their euphemism for oil spills.  The report says there would be a 10- minute response time to stopping a leak.  (Chapter 10, pg 98)Spill Response In light of Enbridge’s safety record, we need to not only consider what they propose to do but how they have done things in the past.  How long did it take to respond to the leak alert on the Kalamazoo River oil spill, AKA The Dilbit Disaster?  Ten minutes? Ah, no.  It was slightly longer.

The first alert came on Sunday, July 25, 2010, at about 5:58 p.m. Eastern time when there was a rupture in Line 6B near Talmadge Creek, a tributary of the Kalamazoo River and a little more than a half mile downstream of the Marshall, Michigan pumping station.  At first Enbridge ignored the alarm.  Then the operators assumed it was a “bubble” in the line so they increased pressure (resulting in more oil spilling faster) for hours.  So when did they finally believe the alarms and shut down the line?  More than 17 hours later.

Yeah, let’s just let that sink in for a moment.  17 HOURS.  That’s a LOT longer than 10 minutes.  Regardless of what Enbridge claims they “will do”, we know what they HAVE DONE and that needs a full review in the DEIS.  A review for EVERY SINGLE SPILL.  Enbridge has a worse track record than their competitors and this should be considered as we decide whether or not to grant a Certificate of Need to THIS corporation.

Also, knowing that it’s only a matter of time before there is a release of dilbit into our environment, should the State of MN decide to grant a Certificate of Need and/or Routing Permit on this project, we need to know exactly WHAT is in this dilbit.  What is dilbit?  It is a form of bitumen (tar sands are pretty much asphalt) that has been diluted with a chemical solution to make it flow through the pipeline.  Without it, the thick sludge Enbridge proposes to transport just cannot move.  It is illogical that a proper evaluation of the environmental impact of installing this line can be done if there is not full disclosure of the products that will be coursing through the pipeline and, should there be a failure, spreading into our natural world contaminating both land and water, animals and people.   The National Science Foundation has already warned of the use of dilbit in areas with high moisture content (i.e., wetlands) due to the way the cathodic protection is affected. Yes, much of the new proposed path lies in areas of wetlands.  And reduced cathodic protection means there will be a greater propensity for pipeline degradation… and thus, leak points.  In addition, it’s been noted that the density of dilbit means it will sink in water, not rise, so how are we to know when there is a release if it all stays at the bottom of the wetlands, creek or river?

If the MN Department of Commerce agrees that Enbridge has a need and allows the pipeline to be installed, the accountability for all spills will land on this Department.  All lawsuits, all cleanup, all injuries and deaths, including those of plants and wildlife, would be the result of the Department of Commerce decision.  When the pipeline leaks, and it will as all pipelines eventually leak, the State of Minnesota will hold all accountability.

It is far wiser to err on the side of caution, especially as the world has already reached peak oil – the hypothetical point in time when the global production of oil reaches its maximum rate, after which production will gradually decline.  We are at the end of the fossil fuel era and any attempt to continue the pursuit of fossil fuels only prolongs the time until we make a transition to renewable energy.  There will come a day when there is NO MORE to suck from the Earth and we humans will have to finally come to terms with the development of cleaner, safer sources of energy.  We will either do it in a way that is planned or in a crisis, but we will eventually convert to renewables.

Minnesota needs to be a leader in this process.  We need to show that hemp is another way to meet our energy needs.  We’ve started that with recent legislation.  If oil spills ruin our farmland, that will be a dead end.  Not to mention the effect on our tourism industry.  We need to continue the path of innovation and energy conservation and abandon the path of dirty oil.  I say that Minnesota must, if morality is to brought to bear, act in the interest of clean water, healthy people, and safe environments.  We need to say NO to another pipeline coming through our state.  And we need to tell Enbridge it’s time to remove the old Line 3 from the ground to assure we prevent ongoing and long-term contamination possibilities.

The above are my comments sent to the Department of Commerce on the Line 3 Replacement Draft Environmental Impact Statement.  If you’d like to send you comments, you need to do so by July 10th.  Email your comments here: pipeline.comments@state.mn.us

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