Yes, those critics who said that if the KXL pipeline were blocked, then tar sands oil exploiters would find another way to get their product to refineries and to market, were correct. At least in part, because Big Oil is not waiting for that decision; they’re already working on developing these alternate routes. (Thanks to
Roger Fox for his recent diary on this general topic, including this map of eastern N. Am. pipelines.)
One of the major routes now under consideration is the so-called “Alberta Clipper,” Enbridge’s Line 67, a pipeline that already stretches from Hardisty, Alberta, to Superior, Wisconsin. It has been operating since 2010 and currently transports about 450,000 bpd. Detroit Free Press
Last November, Enbridge filed an application with the U. S. State Department to request approval for massive expansion of the daily pipeline load. They seek approval for the pipeline to transport the full design capacity of the pipeline, or 880,000 barrels/day (bpd). That is a carrying load, by the way, some 50,000 bpd greater than KXL. Tomorrow, April 29, is the deadline for public comments regarding this expansion.
From the Federal Register (full notice reprinted here):
The purpose of this notice is to inform the public that the Department of State (the Department) will be preparing a Supplemental Environmental Impact Statement for the proposed Enbridge Energy, Limited Partnership, Line 67 Capacity Expansion Project. Under E.O. 13337, the Secretary of State is authorized to issue Presidential Permits for the construction, connection, operation, or maintenance at the borders of the United States, of facilities for the exportation or importation of liquid petroleum, petroleum products, or other non-gaseous fuels to or from a foreign country.
Enbridge Energy (Enbridge) has applied to the Department for an amendment to their current Presidential Permit authorizing it to operate at a higher capacity the existing crude oil pipeline (known as "Line 67''). To approve the amendment, the Department of State must find that issuance would serve the national interest. [emphasis added] In the course of processing such applications, the Department consults extensively with concerned Federal and State agencies, and invites public comment in arriving at its determination. ...
The Department has determined that before determining whether to authorize the proposed higher capacity operation of Line 67 at the U.S. border, it will conduct an environmental review of the Project consistent with the National Environmental Policy Act ("NEPA''). The Department will evaluate the impacts associated with operating Line 67 at its full design capacity of 880,000 bpd.
The purpose of this Notice of Intent (NOI) is to inform the public about the proposed action, announce plans for scoping opportunities, invite public participation in the scoping process, and solicit public comments for consideration in establishing the scope and content of the SEIS [Supplemental Environmental Impact Statement].
Public comments should be sent to:
Written comments or suggestions on the scope of the SEIS should be addressed to: Genevieve Walker, OES/EQT Room 2726, U.S. Department of State, Washington, DC 20520. Comments may be submitted electronically to EnbridgeLine67permit@state.gov.
The Federal Register notice states as well that “Public comments may
be posted on the Web site identified below.”
Let me remind you why this process of public input is so important. In another of Enbridge’s current applications to expand their pipeline capacity, this one being Line 9 between Sarnia and Montreal, Enbridge claims to have contacted several dozen municipalities and First Nations communities in Canada seeking input about their plan. Their report says that only a handful of people, likely fewer than a couple hundred total, have taken the time to participate in the local meetings and to give their feedback.
If this is indeed the case, then think of the potential we have to shift the debate if we contribute comments in larger numbers than they have encountered to date.
Both LakeSuperior and Muskegon Critic have covered this particular issue, Enbridge's plan to expand Line 67, in previous diaries, providing more analysis of the issue than I am offering here. I urge you to read both of their discussions of this vitally important proposal. LakeSuperior’s diary from 3/15 provides the entire text of the Federal Register notice. Muskegon Critic’s diary of 4/16 addresses the terrible risk posed to the Great Lakes by the possibility that a much greater quantity of oil (especially dilbit) will be shipped, literally, via freighters over the Great Lakes in the event this pipeline expansion is approved.
It appears that the hubbub surrounding the #NoKXL campaign overshadowed the possibility of contesting this particular expansion. But it is NOT too late to do so—and your comment(s) can be informed by the content and arguments presented as part of the #NoKXL blogathon.
Please join me after the jump for some suggestions about particular talking points to use in commenting on the Enbridge pipeline expansion, and on a selected list of #NoKXL diaries that might help you craft your comment.
Talking Points for comment:
1. The “Alberta Clipper” (Enbridge Line 67) has been in place for a couple of years, but this expansion is intended to facilitate the transport of tar sands oil in the form of “dilbit” (diluted bitumen), in massively greater quantities than previously done. The change will require additional pumping stations both to carry higher volume and a thicker substance. It is not at all clear in advance that the pipeline is sufficiently secure and leak-free to handle this extra stress.
TAKEAWAY: Legitimate concerns about the technological capacity of these pipelines, in which failure may be rare but catastrophic when it does occur, appear to be minimized. See this report by InsideClimate News about the relatively weak legislation and regulation that have been imposed in the wake of the major Kalamazoo River spill in 2010, none of which would even apply to this stretch of pipeline. Their conclusions are that the latest regulations do not address these potential problems:
1. Pipeline contents still a mystery
2. Little is known about dilbit
3. Deadlines for repairing corrosion and other defects still loose
4. Access to spill response plans limited
5. Spill reporting still lax
Also see point 3 below.
2. The end point of this pipeline is at Superior WI, on the western shore of Lake Superior. Where is the dilbit going after that, and how, to reach oil refineries?
--proposed Calumet dock expansion, to ship the dilbit in tankers (a topic discussed at greater length by both Muskegon Critic and LakeSuperior; please see links above).
--pipelines through the Upper and Lower Peninsulas (see map at the top of this diary)
TAKEAWAY: Insufficient thought has been given to erecting adequate safeguards for the precious and irreplaceable water resource represented by the Great Lakes. Even inland spills are likely to happen near enough to waterways feeding into one of the lakes, to say nothing of the local damage.
3. Enbridge is the pipeline company responsible for “the largest inland oil spill in history,” the 1 Million Barrel plus disaster affecting the Kalamazoo River. Clean-up costs for that event have reached $1 Billion, and the task is not yet done. (See InsideClimate News' Pulitzer-Prize-winning reportage on the spill and cleanup efforts; links to individual articles on the topic available there.)
TAKEAWAY: Even if the technology itself were reliable and failsafe, Enbridge is NOT a trustworthy pipeline operator. They did not respond in a timely way to the first reports of a ruptured line; they did not respond forthrightly to requests for information about pipeline content; their original (and default) response was to minimize the potential for temporary and permanent harm to the affected communities and ecosystems.
Several #NoKXL blogathon diaries, along with a few others that were published on the topic of opposition to KXL during that same stretch, also might be helpful in crafting your comment. My apologies in advance if I have overlooked one that would fit these categories, which is not at all unlikely; please feel free to add your suggestions in the comments if you catch one I’ve missed.
Regarding the negative impact of tar sands mining operations on the Native people living near them—that is, near the same source that will supply this pipeline--including serious health implications:
KXL, a native perspective.... Protecting Mother Earth!! by Marty Cobenais
(It is worth knowing that Marty Cobenais is a member of the Red Lake Band of Ojibwa, who have an ongoing dispute with Enbridge about another of their pipelines which was installed on their tribal territory without their consent. Coverage of their protests is available via the Indigenous Environmental Network.)
Shouldn't We Know Whether Tar Sands Causing Cancer With First Nations Before XL Pipeline Decision? by Patriot Daily News Clearinghouse
Regarding the conditions for ecocide that tar sands mining operations create:
#NOKXL: Dilbit in the Pipeline by Agathena
Keystone XL: Wildlife in the Crosshairs by Target Global Warming
Regarding the dangers of investment in obsolete technology, fossil fuels, instead of investment in renewable energy (increasing our sunk costs in oil):
Reject Keystone XL; Our Focus Should Be on Investing in a Sustainable Energy Future by Representative Barbara Lee
#NOKXL: The Ill-Logic of Keystone XL by Kelly Rigg
Regarding the increase in carbon production as a result of facilitating tar sands mining:
KXL will carry as much carbon as all the cars on the West Coast, plus Michigan, NY, and Florida. by Bill McKibben
#NoKXL: The Future Is In Our Hands; Say No To The XL Pipeline Disaster by beach babe in fl
Climate Letter [to the Editor] Project:
#NoKXL — The Pipeline To Oblivion: Memes From The Climate Letter Project by WarrenS.
Bottom line: It doesn't matter if you're an environmental scientist who can cite chapter and verse of the evidence against tar sands exploitation in multiple categories. What matters is that you are a citizen who is making your opinion known about the potential effect on "national interest" if this proposal is approved.
Thanks for making a comment sometime today or tomorrow!