Enbridge Line 3 Draft Environmental Impact Statement Comments


These are the comments I submitted to the Minnesota Public Utilities Commission on July 10, 2017 concerning the draft Environmental Impact Statement for Enbridge’s Line 3 Expansion Project. I am posting them publicly so that they may be seen and shared, and also to state that these comments were sent to the Dept of Commerce before midnight on the day of the deadline, via their pipeline.comments@mn.state.us email address. Thank you. Miigwech for reading.

Re: CN-14-916, PPL-15-137
To Whom It May Concern:

My name is Natalie Boyd. I am an enrolled member of the Mille Lacs Band of Ojibwe, a resident of the state of Minnesota, a United States citizen, and an inhabitant of Planet Earth. Herein are my public comments in opposition to the Enbridge Line 3 Expansion Project as presented in the Draft Environmental Impact Statement prepared by the Minnesota Department of Commerce Public Utilities Commission. I would like to point out that I am an average citizen with some college education but no expertise in any particular field. These comments are the best I could generate with the time I was given by the state of Minnesota to respond to the release of the draft on May 15, 2017.

This may qualify as my first objection. While I congratulate the state on engaging in the process of developing an EIS for a project of this scope, I feel that the public has been given too little time and information with which to respond. First, the EIS is a dense document and difficult to navigate. The information within it is segmented in confusing ways, and the language used is obtuse. The document, with appendices, is close to five thousand pages long. It is very difficult to address in its entirety. Furthermore, even at this length, the EIS seems to suffer from missing information. There are studies that cannot be accounted for, links that do not work, and relevant information that is simply not provided.

For example, a term used often in the DEIS is Best Management Practices or BMPs. However, the business structure employed by Enbridge and how it will manage ownership and operation of this project are not discussed. It is standard practice with companies like Enbridge L.P. to use Limited Liability Companies to avoid liability for the consequences that would result from a catastrophic failure of the pipeline. This leads me to question who would ultimately be liable for a catastrophic failure of the pipeline in this case. I feel that this information is vital to being able to make comment on this project. If liability is shifted to an LLC, how can taxpayers be sure that they won’t be stuck with the financial burden of cleaning up the mess when the pipeline fails? Enbridge’s business structure related to the Line 3 Expansion needs to be made completely transparent and must be included in documents available to the public, such as this EIS.

Before I go any further, I must make clear one thing. Pipelines always fail. The only unknown factor is by how much. How severe is the damage from the failure going to be? What will the financial cost be? What will the environmental cost be? What will the human cost be?

Let us also clarify another matter. This draft EIS is not an Environmental Impact Statement. This is an Economic impact statement. This document was prepared by the Minnesota Department of Commerce, and all comments have been directed to the MNDOC. By the title of the managing agency alone, it is evident that environmental concerns are not the primary focus being discussed herein. The DOC is rightly involved in some aspects of regulation of this project, being that commerce involves “the exchange or buying and selling of commodities on a large scale involving transportation from place to place,” (as defined by Merriam-Webster.) You will note that mention of the environment appears in no part of this definition. True and actual assessment of environmental impact would better fall to the responsibility of agencies such as the Minnesota Pollution Control Agency, the Environmental Protection Agency, the Minnesota Department of Natural Resources, or any other that has anything at all to do with actual environment. The Minnesota Department of Commerce has a different set of interests it caters to, such as employment and revenue, and the environment is not the primary concern or the purview of this agency.

Additionally, this entire permitting process raises its own questions. As explained in the Executive Summary of the DEIS, the applicant (Enbridge) must first establish the underlying need for the project. Only once the need is established will the EIS be used to make determinations on the manner in which to grant or deny the certificate of need considering all the options and alternatives presented. I am unclear at what point Enbridge has ever first established the underlying need for this project, and I question the validity of this entire document based on the uncertainty of when need was established and when analysis began. (We will come back to the issue of “need” later.)

The first issue I wish to discuss is that of compliance. The DEIS comes to many of its conclusions based on the assumption that Enbridge will comply with all the regulations laid forth in the document. It even goes so far as to make determinations based on the aforementioned BMPs that are not in any way required. The DEIS supposes that Enbridge will always do all that it can to enact good environmental stewardship unless it explicitly claims otherwise. This is a great misplacement of faith.

Enbridge’s spill response plans have not even been developed. They have offered no evidence of comprehensive policies and procedures to deal with “accidental crude release.” It is unquestionable that a release of heavy crude oil, or diluted bitumen, would be devastating. According to “Spills of Diluted Bitumen from Pipelines: A Comparative Study of Environmental Fate, Effects, and Response,” released by the National Academy of Science in 2016, heavy crude oil released in a marine environment poses particular challenges. Weathering of diluted bitumen progresses quickly upon release as the volatiles used to dilute it evaporate, and the remaining residue rapidly begins to submerge. Oil particles may then remain in suspension or sink to the bottom. The study goes on to say:

This situation is highly problematic for spill response because (1) there are few effective techniques for detection, containment, and recovery of oil that is submerged in the water column, and (2) available techniques for responding to oil that has sunk to the bottom have variable effectiveness depending on the spill conditions.”

The United States Geological Survey publication “Oil-Particle Interactions and Submergence from Crude Oil Spills in Marine and Freshwater Environments— Review of the Science and Future Science Needs” goes so far as to say that current techniques that have been developed to deal with suspended or settled oil may be just as or more damaging than leaving the oil in place, and further study is needed.

It’s no wonder then that Enbridge has failed to present spill response plans as effective mitigation tactics do not exist. This does not excuse them from their responsibility for developing these plans. It does, however, call into question whether a project or product such as this should even be considered.

Related to this, the DEIS contains no analysis of the efficacy of Enbridge’s leak detection systems. According to a report from the National Transportation Safety Board on the leak of Enbridge Line 5B in Kalamazoo, Michigan, the leak detection system had no effect whatsoever on the detection of the leak. It was reported by a resident of the area. The Pipeline and Hazardous Materials Safety Administration reported in 2012 that only 17% of pipeline leaks were identified via leak detection systems. This must be taken into account in the DEIS.

Furthermore, the seven sites selected in the DEIS for spill modeling are not representative of the spectrum of resources put at risk along the applicant’s preferred route. The corridor crosses tributaries that lead to Lake Superior, and there is no assessment of potential spill impact to this area. That is a very large body to not have taken into account.

So, what are the consequences if Enbridge does not comply with regulations, and who will be ultimately liable? The Comprehensive Environmental Response, Compensation and Liability Act of 1980, or what we now call the federal Superfund program, deals with the cleanup of hazardous materials. It was initially funded by a tax on companies that produced chemicals, including petrochemicals. This tax was repealed, however, and superfund went bankrupt. As of 2008, Potentially Responsible Parties were not even expected to be entirely fiscally responsible for the cost of clean up anymore. This means that the superfund program is taxpayer funded. We must know if the burden of Enbridge’s non-compliance would fall on the people of Minnesota.

Secondly, I now address the existing Line 3. Though I understand that Enbridge only inspects Line 3 every 12-18 months, I believe it is well understood that the integrity of this line is compromised. The line pressure has been reduced from its original capacity to compensate, but by proposing a new pipeline, even Enbridge appears to agree that this line should no longer be in service.

That being said, Enbridge’s current plan to abandon the pipe in place is completely unacceptable. Enbridge cannot be allowed to walk away from Line 3 with only the claim that they will continue to monitor it. There are too many unknowns when it comes to leaving this pipeline in the ground. This pipe is already exposed on the surface in multiple places, and the proposed drainage of the pipe would only contribute to buoyancy that could cause the pipe to rise in more places. What might happen to these exposed sections? If legacy contamination is discovered, what is the contingency? Enbridge has claimed they would monitor the pipe indefinitely. What does indefinitely mean, and what does monitoring entail? If there is problem in the future, will Enbridge take responsibility for it? Just because they are monitoring the pipeline, does not mean any contamination discovered is not ultimately the responsibility of the landowner on whose property the incident takes place.

If a landowner does not want pipe left on their property, they should not be forced to have it there. [Just as they should not have been forced to accept it being placed on their property in the first place.] Because of the unknown risks of abandonment and to act in fairness toward landowners, the existing Line 3 should be removed from the ground. In response to Enbridge’s claims that removal of the pipeline is potentially dangerous due to proximity to other lines, I would point out that Enbridge already does integrity digs on Line 3, which illustrates that digging up the line is not unknown territory for them. If removal is somehow more dangerous than the thousands of integrity digs Enbridge claims would be necessary to continue operating Line 3, then they must explain why.

Perhaps the most dangerous aspect of allowing Enbridge to abandon Line 3 in place is that there is currently no existing policy for shutting down pipelines in Minnesota state or federal regulations. Whatever is decided here will set a precedent for future cases of pipeline decommissioning. Though it is stated in the DEIS that only this specific case can be addressed, the future impact of these decisions must be taken into account. Petrochemical and extraction companies must be shown that they are responsible for cleaning up their messes.

It has often been pointed out that many Minnesota counties have benefited from Enbridge’s tax contributions. This is said to illustrate the financial benefit Enbridge provides to rural Minnesota communities. However, the Star Tribune reported in March of this year that Enbridge disputes taxes levied over the last decade. The case has gone to court, and if Enbridge wins, Enbridge will receive millions of dollars in back taxes–taxes taken back from the counties it supposedly helped. This is the kind of corporate citizenship we can expect from Enbridge. This corporation cannot be trusted to keep the promises it makes.

Enbridge also cannot be counted on concerning the argument that pipeline construction would provide Minnesota an economic boost, even temporarily, by providing jobs. This financial benefit would go to a transient workforce and have very little effect on Minnesota households. This is explicitly stated in section “…hiring of local residents […] would have a temporary and negligible impact on county-level unemployment or per capita and/or median household income levels.” It is expected that the majority of the workforce will be relocated to the areas of construction for the project, meaning employment revenue will return home with them and not stay in the Minnesota economy. Furthermore, the Line 3 expansion will create virtually zero permanent jobs. According to the same section of the DEIS, “operation of the pipeline would have no measureable impact on local employment, per capita household income, median household income, or unemployment in the ROI.” The fallacy that this project would create jobs that will benefit Minnesota residents on a large scale must be corrected.

The third major deficiency of the DEIS is the lack of analysation for a true “no build” alternative. If we pretend for a moment that this document is part of a procedure for assessing the need for and alternatives to new methods of transporting heavy crude oil across the state of Minnesota, then it has entirely forgotten to consider the alternative of renewable energy. In section 5.1.3, the applicant’s preferred route is compared with the alternatives of “continued use of existing Line 3, System alternative SA-04, Transportation by rail, Transportation by truck, Existing Line 3 supplemented by rail, Existing Line 3 supplemented by truck.” Route segment alternatives are also elsewhere discussed, but nowhere is the alternative to not increase the amount of oil currently crossing the state ever considered.

The United States, and the rest of the world, is currently experiencing an oil surplus. Oil companies have even agreed to lower production in order to artificially inflate the price of oil and raise their profits. According to the USA Today, the oil market is suffering from “chronic oversupply.” Yet Enbridge, a Canadian company, continues to assert that their existing pipeline systems are not able to meet the demand for oil. (Section 2.2) Enbridge needs to clarify what demand they are referring to, because all evidence seems to point to the contrary.

We also don’t know the market destination of this product. Enbridge claims that much of it is bound for U.S. use, but this may not even end up being domestic product. The public needs to know where this oil will be going, lest Minnesota simply become a dangerous conduit to serve a foreign company’s profit.

The important point here is that the need for expanded oil transportation capacity, which is what this is presumably all about, simply does not exist. And even if the demand for oil were as high as Enbridge claims, renewable energy alternatives to petrochemicals do exist. From transportation to power generation, the technology exists to move away from fossil fuel dependence. The only reason fossil fuels are still the dominant energy source in the world is because oil companies suppress alternative energies. In order to protect their profit, oil companies lobby against, buy out, and bully competitors developing renewable energy. No one disputes that modern civilization is dependent on energy in ways we never have been before. By assuring that access to and further development of alternate sources is limited, the petrochemical industry effectively holds the world hostage. We turn to petrochemicals because of a lack of choice, not because other options don’t exist. The demand for oil is completely artificial, engineered by the greed-motivated fossil fuel industry.

The fourth major shortfall of the DEIS is that its impact assessments are insufficient. Chapter 5 is full of language such as would, may, where feasible, generally, typically, and other non-conclusive phrases. It also seems to almost always come to the conclusion that potential impacts would be “temporary or minor.” Direct impacts are discussed “where feasible” while indirect impacts appear to be given much less weight and will only be “described where appropriate.” (5.1.3) Though an impact may be indirect, that does not mean it will not have an equal or greater effect than a so-called direct impact. There is an entire branch of mathematics dedicated to the study of causality and behavior in dynamic systems. The Fractal Foundation, a teaching organization that explores the science known as Chaos Theory, claims that “By understanding that our ecosystems, our social systems, and our economic systems are interconnected, we can hope to avoid actions which may end up being detrimental to our long-term well-being.” By compartmentalizing impacts in the way that the DEIS does, the interconnectivity of the ecosystem (which includes humans) is ignored.

In bedrock aquifers are mentioned and then summarily dismissed. The DEIS states that “bedrock aquifers are not expected to be affected by pipeline construction and operation because they exist at depths averaging from 300 to 400 feet, which is well below pipeline construction depths. […] Groundwater in these rocks occurs mostly in fractures that may not yield usable quantities of water.” The message here appears to be that bedrock aquifers along the applicant’s preferred route are not likely to be at risk, but if they are negatively affected, their water supply is beyond feasible retrieval. It’s ironic that the amount of oil found in fractures is considered a “usable quantity,” but the amount of water is not. The oil that would be transferred through the applicant’s pipeline is retrieved from fractures. It should be kept in mind that if surface water and other more conventional sources of groundwater were to be contaminated by the applicant’s product, these bedrock aquifers could be the only source of water left. These sources should not be disregarded as low risk.

Chapter 5 demonstrates that the DEIS suffers from a misunderstanding of how ecosystems operate. In the discussion of surface water impacts in, the Region of Interest (ROI) assessed is limited to “the construction work area for each surface water crossed by the Applicant’s preferred route in Minnesota (typically 120 feet wide) as well as the area immediately downstream from the crossing for flowing surface waters, and in the immediate vicinity for crossings of non-flowing surface waters such as lakes and wild rice waterbodies.” This statement shows either willful or fundamental ignorance of how the biosphere functions and also of the meaning of the word downstream. A stream is defined by Merriam-Webster as “1. a body of running water (such as a river or brook) flowing on the earth, 2. a constantly renewed or steady supply, 3. an unbroken flow, and 4. a dominant influence.” Streams do not stop flowing “immediately downstream” of anything. Neither can it be said, due to fluid dynamics, that something that may affect a non-flowing body of water can be contained to that “immediate vicinity.” The ecosystem is vast and interconnected. It is much like a web; if you pluck one string, you distort the whole structure. To say that impacts would be localized in the manner that the DEIS claims is fallacious. The fact is that, as was chanted at Standing Rock, we are all downstream. This means that impacts, wherever they occur, will have a trickle down effect on us all, on a broader scale and in ways not examined in this DEIS. This is a crucial failing of this document that must be addressed.

A cathodic protection system is briefly mentioned in section as part of the mitigation measures taken to protect the pipeline from co-located electric transmission lines that could contribute to corrosion. However, this system is not required to be in place until up to a year after the pipeline is constructed. This could result in the development of pinhole leaks, which could be considered more insidious than a large spill, as they would be more difficult to detect and remedy. Installation of cathodic protection must occur immediately following pipeline construction.

The fifth flaw in the DEIS concerns environmental justice. I would first like to point out that the classification of low income in 11.2 is important because it illustrates the wide gulf between Enbridge as a multibillion dollar corporation and the average citizen of Minnesota. The people of Minnesota are the affected parties when it comes to this pipeline being expanded in the state. It is our well being that is at stake. Compared to the megalith that is Enbridge, we are all low income, no matter what metric is used. Average Minnesotans will never have the resources to deal with Enbridge on a level playing field. This is especially true for individuals who are against the pipeline expansion. Beside a voice, there is virtually nothing we can bring to bear against Enbridge, and there is no justice at all in those kinds of odds.

Specific to the DEIS, section 11.5 is problematic because it describes mitigation measures that can but not necessarily will be considered by the Certificate of Need or Route Permit decision. These are descriptions of possibilities, and there is nothing that guarantees follow through. Without explicit procedures outlined and required, these measures amount to lip service only.

Enbridge also makes clear that it intends to do as little as possible in terms of remediation. Biological systems are delicate, and even with BMPs and everything going according to plan, there is no disputing that ecosystems will be impacted. Section summarizes the Wetland Conservation Act and its requirements but concludes with the information that “Utilities, including pipelines, […] can request exemption from wetland replacement requirements, and Enbridge has indicated that they will seek this exemption.” Even if full standard practices were used, it could take decades for affected wetlands to recover, yet Enbridge doesn’t even intend to do that much. This is unacceptable. Enbridge must not only promise to complete all known remediation measures for environmental impacts, but they must provide detailed plans on how they intend to do so in all biomes that will be affected.

The sixth major issue with the DEIS could be considered several issues, but all fall under Tribal Impacts, even if they were not organized that way within the DEIS. Because of the obscure way tribal impacts were addressed in the DEIS, there was a general lack of continuity concerning many issues. This amounted to large quantities of information that mask the fact that the DEIS does not provide any suggestion of meaningful action to mitigate tribal impacts. In this way, the DEIS shows a continued disregard by the state of Minnesota for issues that affect indigenous communities.

One glaring problem is that the archaeological surveys used in the DEIS were provided by Enbridge and are therefore not independent. Furthermore, some can no longer be accounted for. In section it’s stated that the applicant is encouraged to consult with the Minnesota State Historic Preservation Office–encouraged by not required. The applicant’s preferred route crosses multiple cultural corridors, regions culturally significant to tribes, as defined in 9.4.2. The Minnesota Indian Affairs Council “recommends a complete survey of the entire proposed route; this survey should occur prior to the start of any construction as it will involve gaining input from a number of tribal communities and gathering their oral histories to assist with the identification of these places.” This has been recommended but, of course, has not actually occurred. It is an afterthought of this process and still not a factor in any decision making.

Along with cultural corridors, the applicant’s preferred route puts many wild rice lakes in jeopardy. In fact, it threatens the most of any of the assessed alternatives. As a food staple and spiritual source for indigenous communities, wild rice is invaluable. Any loss to wild rice habitat would have a devastating effect on tribal communities. This is the only place where this sacred food occurs naturally. Tribal communities have already suffered disproportionately from colonialism and industrialism. The DEIS acknowledges that any of the possible routes for Line 3 “would have a long-term detrimental effect on tribal members.” As per 11.5, however, a finding of disproportionate and adverse impact “does not preclude selection of any given alternative.” The DEIS blatantly indicates that the state of Minnesota will disregard threats to tribal communities.

Section delineates the steps and permitting requirements mandated by the Endangered Species Act for the project’s potential impact on “federally listed threatened or endangered species, candidate species, species proposed for listing, and their designated critical habitats.” There are protections in place for threatened species of animals in the United States, but there are not for indigenous people. The United States government has done everything in its power to eradicate America’s native tribes, and by a global perspective, it has nearly succeeded. America’s indigenous people represent less than .07% of the world’s population, based on the 2010 US Census. While the US government claims to now have a fiduciary relationship with tribes and to act in their best interests, it’s evident that state and federal agencies have merely adopted an appearance of respect while continuing to enact policy that damages native communities. The dismissiveness of this DEIS is part of that policy.

The impact of temporary workforces associated with pipeline construction are of great concern to tribes. As stated in 11.4.1 “Increases in sex trafficking, particularly among Native populations, are well documented. […] The addition of a temporary, cash-rich workforce increases the likelihood that sex trafficking or sexual abuse will occur. Additionally, rural areas often do not have the resources necessary to detect and prevent these activities.” This phenomenon is no more evident than in the Bakken oil territory, and it is an ongoing problem in North Dakota’s oil fields. Young women and girls on the Fort Berthold Reservation are afraid to walk down the street there, knowing they can be taken at any time. Violence against women is already a major concern in Indian country due to the effects of abuse that began in boarding schools and were perpetuated in the trauma cycle that followed. Missing and murdered indigenous women has its own Wikipedia page, chronicling the issue.

Enbridge and the state of Minnesota, however, seem dismissive of this issue, suggesting that “Enbridge can prepare and implement an education plan or awareness campaign around this issue with the companies and subcontractors that construct, restore, and operate the pipeline, as well as by working with local communities and tribal communities to raise awareness and provide resources to address the issue.” (11.4.1) Indeed, these measures can be taken, but whether or not they will be is undetermined. Once again, the DEIS is offering potentially empty promises, this time on an issue that could mean nothing less than life or death for individuals affected. Even if we could trust Enbridge to follow through on these suggestions, what difference could we expect them to make? The workforce in question would be subcontracted to Enbridge, and Enbridge would not be liable for them. These measures are woefully insufficient. Enbridge needs to promise that it would take steps to monitor its workforce, investigate crimes, and prosecute its employees if applicable. It needs to lend monetary resources to local law enforcement agencies to help curtail crime. It needs to create a victim support fund, in addition to making support resources available in local and tribal communities. These things all need to be requirements. Even one case of sexual violence is one too many. Whatever psychological impacts may be suffered during this construction phase will be long lasting and yet another imprint of trauma on the native community.

And trauma is really the most obvious and unavoidable impact that construction of any new pipeline in the state of Minnesota would have on indigenous peoples. It is commonly accepted nowadays that historical trauma is a real crisis that affects chronically oppressed peoples. There is fair mention of historical trauma and the structural racism suffered by tribal communities. The DEIS even acknowledges that “the proposed Project and its alternatives would be an additional health stressor on tribal communities that already face overwhelming health disparities and inequities.” (11.4.3.) What the DEIS doesn’t seem to recognize, at least explicitly, is that the extraction industry across America is inflicting trauma on native peoples in the present tense. It cannot be dressed in alternate language like stressors or impacts. These are traumas, which are to the native spirit, as much like wounds as a gunshot would be.

One need only look as far as North Dakota to see how deeply affected indigenous communities are by the toxic industries that run through our land. Our land is part of us, inseparable from our sense of self and livelihood. We are the land. Native Nation’s collective response to the Dakota Access Pipeline said all that needs to be said about our sentiments toward pipelines. Our shared experiences, however, also created a new generation of trauma in our communities. People from native communities all over the United States visited Standing Rock, including myself and many others from the state of Minnesota. Many of us returned to our home reservations having experienced humiliation, intimidation, vilification, and physical injury–all at the hands of government agencies acting in the interests of petrochemical companies. We have returned home bearing not only our historical trauma but a new kind of post-traumatic stress disorder. And Enbridge’s Line 3 Expansion project will only add to this trauma.

Closer to home, in Minnesota, the extraction industry has already had a huge impact on our state. Our so-called Iron Range is covered with open pit mines that are like vast sores on the skin of the land. These mines leave behind dead zones, as will the pipeline in the event of failure. These are wounds in the earth and wounds in the souls of native peoples. We know this threat, and we will do all that we can to stop it. None of the impacts of any of this will be, as the DEIS often repeats, short term or temporary.

The overarching problem with the DEIS is that it entertains permitting a project which supports the tar sands industry. This document is supposed to weigh the cost of a project versus its benefit, and when you consider the origin and nature of this product, the cost becomes insurmountable. Globally speaking, climate change is the single greatest threat humanity has ever faced, and the most dangerous aspect of this battle is that many people do not recognize this threat. The petrochemical industry, as a whole, denies the threat of climate change.

As I wrote above, ecosystems are incredibly delicate. Our entire planet is one very large ecosystem that has evolved naturally over the course of billions of years to arrive at this place where it is perfectly suited to support human life. It has taken us barely more than two hundred years to bring our planet to the edge of irrevocable change. Climate change could have devastating consequences for not only humanity but for all life on the planet. With the possibility of temperature changes, oceans rising, and weather systems intensifying, it’s difficult to predict the odds of anyone’s survival. That is, if we do not do all that we can to prevent further impact on the climate.

Curtailing our use of fossil fuels is the number one thing we can do to avoid this disaster. The carbon emissions from fossil fuels exacerbate climate change each day that we continue to use them. Tar sands oil is the dirtiest fossil fuel to produce, and the end product further contributes to carbon emissions in its use.

Local to the area of production in Alberta, byproducts of this heavy-crude oil are already killing wildlife and area residents. Tar sands extraction has left a swath of devastation in its wake with toxic tailing ponds, contaminated water sources, decimated landscapes, poisoned wildlife, and beleaguered communities. It has also exacted a high cost on Canadian First Nations (indigenous) communities, where their water has been compromised and depleted, and they are experiencing rare and unusual forms of cancer associated with the toxins from tar sands extraction. The potential geological impacts of the extraction process, which involves hydraulically fracturing bedrock, are not even known. This is a lethal product. Heavy-crude oil, or diluted bitumen, acquired from Alberta’s dirty and destructive tar sands, should not ever be transported through or utilized in the United States. It’s dirty, dangerous, and damaging to indigenous people.

In conclusion, I strongly suggest that this EIS explore the field of renewable energy and present it as an alternative to the expansion of the petrochemical industry. Not only is renewable energy better for the environment, but jobs in renewable energy, such as wind and solar, are growing at a rapid rate and represent a better opportunity for long-term employment. Renewable energy will also be more cost effective in the long term, as it does not require the development of new infrastructure to chase new and progressively harder to reach fuel sources. There is no limit on what technology and renewable energy can accomplish going forward. From solar roads to micro-turbine wind trees to algae powered lamps, the possibilities are endless.


Natalie Boyd

For the record, this was submitted to:
Jamie MacAlister
Environmental Review Manager, Minnesota Department of Commerce
85 7th Place East, Suite 280
St. Paul, MN 55101-2198
Fax: (651) 539-0109

I hope this is informative and helpful for someone. Expect more information from me as the permit process for this pipeline moves forward. We (MN residents) are expecting the final EIS within the next couple months, and as I understand it, have been given a week to review this 5000 page document at that point to see what, if any, changes have been made. Hopefully, this will be amended, and we’ll be given more time.

Thanks for having a look at these comments.

One thought on “Enbridge Line 3 Draft Environmental Impact Statement Comments

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