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The Draft Environmental Impact Statement Public Comments are in and I’ve read hundreds of pages of commentary from my fellow Minnesotans and others who have expressed concern and support for Enbridge’s proposed Line 3.  Mine is not a thorough analysis as there are thousands of pages of commentary to peruse and I’ve only seen the tip of the iceberg.  However, I thought I would provide a brief update from my explorations.

The comments have been published alphabetically by submitter’s last name.  In the case of organizations, they are listed by the organization’s name.  I received eight email messages of the comments, each with a listing of files.  The first email included:

  1. DEIS – Local Units of Government
  2. DEIS – Federal Agencies
  3. DEIS – State Agencies and Legislators
  4. DEIS – Fond du Lac Band of Lake Superior Chippewa
  5. DEIS – Leech Lake Band of Ojibwe
  6. DEIS – Mille Lacs Band of Ojibwe
  7. DEIS – 1854 Treaty Authority
  8. DEIS – White Earth Band of Ojibwe

The third email had:

1) DEIS – Citizen Written Comments, A
2) DEIS – Citizen Written Comments, Anonymous, Part 1 of 2
3) DEIS – Citizen Written Comments, Anonymous, Part 2 of 2
4) DEIS – Citizen Written Comments, B
5) DEIS – Citizen Written Comments, C
6) DEIS – Citizen Written Comments, D
7) DEIS – Citizen Written Comments, E, Part 1 of 3
8) DEIS – Citizen Written Comments, E, Part 2 of 3
9) DEIS – Citizen Written Comments, E, Part 3 of 3

Comments from the letter H took up three of the email notices with 20 sets of documents total.  The eighth email covered letters R-Z.  But I want to talk about the G letters.

I was tickled to see Dan’s letter first, followed by mine.  We both sent several pages of input: science and emotion, along with DEIS page numbers to which we referred.  We’d put some time, thought, and consideration into the letters we sent.  I was surprised to see an almost even response in the Pro-Pipeline and Anti-Pipeline comments.  But when I looked at the detail, here’s what I found.

Occasionally a letter was hard to tell whether it was positive or negative to the pipeline but with a bit more reading and investigation I was able to classify them all in the end.

The number of Pro-Pipeline comments was 34 while Anti-Pipeline had 37 comments.  This seems like even support for both options on its face.  But a deeper look reveals some interesting detail.  Also, as I paged up and down through the letters in writing this blog, I realized some people had provided input multiple times.  If we remove the duplicate entries from the same person, the Pros go to 32 [one guy sent in two pre-printed cards, though he did have different comments on his cards; the first said “Pipelines suport good paying jobs. They Also put alot of money into Local economy!” and the second said, “I support the Line 3 project.  It produces good jobs!” – at least he spelled ‘support’ correctly the second time around] and the Antis go to 31.  [More on this below.]  For analysis purposes, I counted each response individually, even if it was one of three responses from a given individual.

Of the 34 support letters, 24 were simply Pro Pipeline G Cardpre-printed postcards, many with little or no comments at all, just a name, address and phone/email.  Three were DEIS Public Meeting Comment Sheets (papers provided at the public open houses for people to provide commentary).  Five were emails and two were letters.

Compared with the letters speaking to opposition to the Line 3 project, there was only one pre-printed card and even it had some commentary.  There were two DEIS Public Meeting Comment Sheets, one handwritten letter, and 32 emails, many of which were multiple page documents.
Anti-Pipeline G card

Looking solely at the pages of input, there were 89 pages total.  Each email had its own page in the document, as did each pre-printed card.  There were 34 pages for Pro-Pipeline, and 55 pages for Anti-Pipeline.  Dan and my letters accounted for seven of the pages.  Ken Graeve of St. Paul accounted for seven pages on his own but did so via three messages, each with a different focus: one on invasive species and the threat to agriculture and forestry industries in Minnesota; one on energy policy and whether this “facility” can comply with relevant policies, rules, and regulations of other state and federal agencies and requesting a review of alternative energy sources; and one on the flaws in the DEIS analysis of impacts to wetlands from inconsistencies in the reported acreages (313 in one table and 440 in another) to the failure to consider hydrologic connectivity of wetlands to false assumptions made about stormwater runoff and erosion.  Ken’s professional experience lies in the fields of ecological restoration, environmental compliance on construction projects, and invasive species control and prevention.

Other Anti-Pipeline multiple submissions were made by Jo George, Eileen Grunstrom and Roger Grussing of Pillager. Roger focused on the same issue of “4 times safe” rules which should be required of pipelines in both submissions but he provided an email and a more detailed DEIS Public Meeting Comment Sheet.  Eileen submitted support of the Friends of the Headwaters stance in opposition to the pipeline with a list of the many waterways at risk in the corridor and then replied with additional personal information for consideration asking in the end, “What kind of legacy am I leaving to my children and grandchildren?” Jo George of Minneapolis noted three focuses in as many contacts:  what the state (not national) need is for the pipeline in light of falling fuel demand; the absence of spill data provided by Enbridge (much of it was redacted from the public information shared); and consideration for the greater economic picture including fishing, tourism, and recreation industries among others.


On the Pro-pipeline side, the two multi-submissions of two individuals account for their loss of two counts.  Similarly to Eric Gulland of Duluth, John Gilbertson of Puposky submitted two pre-printed cards: one with no comment and one stating: “It is rediculos that all these meetings need be. After 60+ years of using pipelines to move oil, without a doubt its proven to be by far the safest way. Everything is in place lets get to work.”

I did read most all the letters for the R-Z section and one of my favorites was this from David Reisenweber of Duluth: “It’s really stupid to run tar sands oil through water rich Mn.”  He pretty much states the obvious simplicity of this debate.  Water is life.  The oil, tar sands not the conventional crude with which Minnesotans have a long history, is not destined for us but will most likely end up as exports to China.

The Sierra Club gave me high hopes with their exhaustive (33 pages of legalese) explanation on how the Department of Commerce’s (DOC) DEIS did not meet the MN Environmental Policy Act (MEPA) requirements of an EIS and that there were multiple failures in methodology for evaluating impacts.  They soft-pedaled their criticism of the DOC in saying these errors are due to the highly complex nature of an EIS, especially considering the “scale and range of the project and the many impacts to water, land, air, health, safety, security, and communities”.  Sierra Club encouraged “the Department to prepare a new DEIS in close coordination and consultation with the Department of Natural Resources, the Pollution Control Agency, and other agencies who can lend both their knowledge and experience on how to prepare an EIS so that it complies with the requirements of MEPA “.

I’d second that.