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As I did on a previous session of public comments on the Enbridge Line 3 proposed new line project, I am again reporting on the nature of the data for this latest round of Revised Final Environmental Impact Statement (RFEIS) Public Comments for the Public Utilities Commission (PUC).

Yes, I am a glutton for punishment!!  But I am also a curious fuck and wanted to see what the commentary looked like for several reasons.  I suspected that, like last round, the Pro-Pipeline commentary would be very terse, uninformed, and belligerent.   I expected the Anti-Pipeline people to be more educated, verbose, and supportive of Indigenous Rights.

What did I find?

The Pro-Pipeline was definitely short and somewhat ignorant but not nearly as hostile as I suspected it would be.   The Anti-Pipeline was largely as expected.

Here are the details.

The listing indicated that 180 individuals had submitted comments.  I ended up with a few more so I’m not sure if this is their miscount or mine but with several hundred pages of letters, I’m not gonna be super nit-picky with the details.  I’m providing this review as a way of showing qualitatively how the two sides compared.  But if you want to count them, here they are [and yes, they AGAIN listed my name incorrectly – sheesh!]:

Mary Adams Lisa Havelin Mary-Churchill Peeples Vicki Andrews Gary Heimark Sheila Perrington Elizabeth Baker-Knuttila Ann Hess Cheryl Peters Steve Bakkum Janet Hill Doug Peterson Kathryn Beatty Jenny Hill John Pettingill Bill Bennett Kathy Hollander Joni Phillips Shannon Benzer Julie Huber Greg Pierce Ric Berkholtz Neal Illes Debbie Prestby Paul Berland John Iversen Richard Preston Reece Bertholf Carl Jarvi Curtis Proud Mike Birkeland Gary Jepson Cynthia Purchase Michael Blandford Chad Jewell Casey Quinn Dean Borgeson Barbara Job Ranee Raddohl Frank Bowker Al Johnson Rose Ragole Diana Brainard Deanna Johnson Phil Randall Annelise Brandel-Tanis Glen Johnson Kate Richardson Dave Butcher Matt Johnson Jim Roberts Mary-Kay Byers Rachel Johnson Deb Rogers Aaron Camacho Thomas Johnson Lora Schroeder Robert Chastan Bryn Johnston Leah Shwer Jaci Christenson Emily Jurgens Jennifer Smith Cyril Christo Daniel Kelley Rebecca Smith Nick Compton Matt Kesner Daniel Snidarich Michelle Crawford Kathy Koch Loren Solbergf Anne Cremons Dave Kotula Ashley Stalvig Alan Crompton Rachael Krivinchuk Michael Stang Lois Dalsin Jason Kruse Charles Staten Judy Diaz Kathy LaBerge Amy Stenseng Jimmy Dick Kathy Labriola Craig Sterle Tess Dornfield Philip LaFlamme Bud Stone Mary-Theresa Downing Craig Larson Richard Stuckey Jay Doyle Randy Lasky Walter Suronen Janet Draper Kurt Lauderbaugh Dean Swenson Eleanor Dvorak James Lawson Nancy Terhark Chris Elliot Sharon LeMay Mel Thoreson Nicholas Eltgroth Trevor Lindblom Gary Tibbitts Torrey Erickson E Lindell Jim Tjepkema Bill Erzar Gudrun Lock Jessica Tobin Jeanne Fahlstrom Mary Ludington Shelly Tocchio Lory Fedo Jason Markert Greg Todavich Cynthia Finch Terri Mathis Susan Tomte Brian Foster Nathan McKinney Bailey Troth Jamie Gaither Nancy McReady Peter Tuitt Shaun Germolus Brian Meier Wendy Ulrich Kerry Gersich Jorie Miller Joe Van Vynckt Chad Gilbert Keith Miller Nick Voss Steve Giorgi Kevin Miller Wendy Vyskocil Dawn Goodwin Mitch Mincoff Don Wagner Dylan Goudge Melodee Moniken Justin Wallace Mike Gragert Michael Monsrud Phillip Wallace John Grover Boucher Mooney Corey Weber Katie Grymala Tom Morgan John Weber Paul Gustafson John Munter Joe Wenker Shannon Gustafson Sharon Natzel Josh Yank Jaqueline Hadfield Nancy Norr David Ybarra Fredrick Hage John North Koh Zhi -You Shauna Haines Kevin OConnor Raymond Zidrick Patricia Hammel Gary Oja Tony Hansen Connie Olson Kelly Harrington Kevin Olson Brian Hartje Teresa Paris

Of the 192 submissions I counted, I found one Pro-Pipeline guy had submitted his commentary – the same letter – three times.  On the Anti-Pipeline side, there were two repeaters, one woman who submitted the same letter twice and one man who submitted two letters of substantially different material.   There were a total of 114 Pro-Pipeline and 78 Anti-Pipeline submissions.

In all, there were ~264 pages of letters from individuals.  [Note – one Pro-Pipeline submission  had about 10 blank or only a couple meaningless word pages in it, which I didn’t count. Looked like an internet issue.] Some of these letters were full pages and some were one line letters.  In trying to be fair about the counting, I would give a 3/4 page Pro-Pipeline letter a full count but if it was 1/2 page, only half.  For the 1-2 liner messages, I gave them 10% of a page – even though it was not truly that substantial.  And even the three-six line comments got 20% or 25% of a page.  I tried to count letters as 1/4 page, 1/3 page, 1/2 page and 1 page as best I could.

In all, the Pro-Pipeline folks submitted 36 pages of commentary.  Of these, 46 of the submissions were three lines of text or less.  Just for curiosity’s sake, I went back through the 264 pages and counted… 22 single line submissions (all but one Pro-Pipeline). Here are some of my favorites [No, I did not alter the punctuation, grammar, or spelling in any of these… and yes, these are the complete letters excluding the greeting/closing]:

  • I am a Minnesota resident and 100percent for the replacement of line 3 and for the positive help to are local economies and the taxes that help the school district in the county that they cross
  • I am in full support of line 3 replacement!
  • this project needs to be completed ASAP!  [This exact verbiage was submitted twice, both without the capital letter to begin the sentence.]
  • Build it and pull the old one out to create more job and help the economy in the area plus it will be a safer line with better coating and steel
  • The EIS is more than adequate, the law’s been followed, grant the permit.  [Should I have counted this as a 3-liner???]
  • JBW Consultin LLC fully supports the Line 3 endevour.  [This appears to be someone hoping to capitalize on the “endevour”…  Let’s hope their “Consultin” skills are better than their English skills.]
  • This line replacement is an integral part of repairing America’s Infrastructure!!!

This was probably the best written of them all:

  • It is in our community’s best interest to allow replacement of the Line 3 pipeline in a timely manner to enhance the safety of the pipeline and to reduce maintenance activities that disrupt landowners and the environment.

[I also counted about nine 2-liners, so… sixteen 3-liners.]

Here is the Anti-Pipeline 1-liner I found (I’d originally counted it as a Pro letter – my bias is showing!!)

  • Line 3 makes no sense not only from an environmental and native rights standpoint, but also fro the economic standpoint of investing in an outmoded energy resource.  [So our side has typos too!  But at least I am now unconfused about a Pro-Pipeline letter referencing Indigenous Rights…]

Here’s one of my favorite short ones from the Anti-Pipeline side:

Tar sands…
> are a dirty and inefficient source of energy,
> will hurt the environment through climate change,
> and use land in violation of existing treaties.
Please do not approve a continuance of this offensive, opioid-like addiction.

Only 19 of the Pro-Pipeline submissions were more than a half-page in length and I don’t recall any being longer than a page.  I would say 12-15 were full-page submissions (again, if it was 2/3-3/4 page, I gave them a full page credit) but the majority of the submissions were very brief, 5-6 sentences or less.

As to the uninformed charge I make, I give this as an example of a Pro-Pipeline sentiment:

This is a long overdue needed line . The old line is failing and constantly being repaired . I c these things as I locate utilities for all pipeline projects in my area . The safety programs these guys put in place are top shelf .the environmental issues are above and beyond what’s required and the safety concerns of the pipeline are met
constantly with new technology and old they upkeep and inspect these line like no other . The money that this will bring into areas along it’s route will not only thrive while it’s going through but the tax base it will provide after that is detrimental to all plus it will employ and help our economy . Build it build it build it

OK, I admit, when I saw “Build it build it build it” as an ending to a letter, I knew I’d be picking it.  Now, reading it through, it shows some of the ignorance but really, I’m seeing how hard this is to even decipher!  What’s uninformed here?  Yes, the original Line 3 is old (and had quality issues when it was built because no one thought dropping pipes as they handled them might lead to issues down the line).  And it is constantly failing and needing repair, especially since they are pushing Tar Sands.  BUT I’d take issue with Enbridge’s safety programs.  They are NOT top notch.  In fact Enbridge has one of the worst records in the industry.  They do inspect lines but… we still have failures that are not detected by these inspections.  Best available technology does NOT mean sufficient and competent technology, just the best we’ve come up with to date.  As far as the money the pipeline will bring into the area?  Temporary jobs do not provide long-term economic support and while he says the tax base will be “detrimental”, I think he means the opposite.  And yes, I know I will pay higher taxes if a new pipeline doesn’t come through and provide.  But I’m pretty sure the risks to our much bigger economy of tourism are not worth chancing for a few jobs.  And I’m willing to pay higher taxes.

Very few of the Pro-Pipeline letters actually addressed what the PUC was requesting, whether the RFEIS addressed the four points that the PUC deemed Inadequate in the FEIS.  Most were about pipelines being the safest transport for oil, how we really need the jobs (though many will go to non-Minnesotans), energy independence (“It is time we get to the point where we’re not depending on other countries oil. Countries that fund the exact terrorism that is killing people every day!”), and how we all use oil and its products every day (“These include computers, cell phones, beauty products, appliances,
clothing and sporting goods.”).

So how many pages did the 78 Anti-Pipeline folks submit?  About 92.  Yes, 2.5 times the number of pages submitted by 40% less contributors.  On average, more than a full page per submission.  Yes, we had a few of our own short and poorly written letters and some were simply supporting the environment or Indigenous Rights.  But, by and large, the data in our letters was substantial, referencing links, news articles, and the page references in the RFEIS in question.  Most of the letters actually addressed the four items in question by the PUC.

I was pretty proud of the Anti-Pipeline showing.

When it came to form letters, Enbridge had given up on this tactic.  No pre-printed postcards for this round on the Pro-Pipeline side.  While this blog only concerns itself with self-directed letters submitted to the PUC, MN 350 and Interfaith Powe & Light did submit some pre-printed forms.  They were tallied in subsequent batches of Public Comments. As in the last go-around, many of these cards/petitions also contained verbiage, not just signed names and addresses without comment.  How many did they submit?  Over 23,000 citizens agreed that Enbridge’s New Line 3 is not good for Minnesota’s future.  Yes, the Anti-Pipeline submissions definitely surpassed those of the Pro-Pipeliners all-in-all.

As to the belligerence?  It was really not as bad as I thought it might be.  I recall one Pro-Pipeline letter saying something about putting “politics aside” and some stressing that this project has been on hold long enough.  But for the most part, the letters were civil on both sides.  Most of the outrage on the Anti-Pipeline side was regarding the racism (some called it by name) of not giving Indigenous People a voice by including a Traditional Cultural Properties Survey in the EIS or lamenting the little time left if we truly want to address climate change.  But even when an Anti-Pipeliner was short and forceful, they were often still polite…

I OBJECT- Before the Administrative Law Judge tries to make her findings, I request that you create a supplementary EIS that addresses the deficiencies in the Final EIS. Please.

So here’s the summary:

Pro-Pipeline: 114 letters, 36 pages, 21 one-line submissions, 9 two-line submissions, 15 three-line submissions, little data but lots of unsubstantiated statements.

Anti-Pipeline: 78 letters, 92 pages, 1 one-line submission, many multi-page submissions, lots of evidence backing up the statements saying that the RFEIS continues to be inadequate.

Seems like a no-brainer to me.  Deny the Certificate of Need.  Kick Enbridge’s New Line 3 Tar Sands Pipeline to the curb.

Update 3/15/18: The public Utilities Commission voted to accept the RFEIS as Adequate. You can read more on my FB post from that date.