Add your voice to stop the Line 3 tar sands pipeline!

Minnesota Department of Commerce

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A month ago, a group of 13 Minnesotans between the ages of 16 and 23 took bold legal action to oppose Enbridge’s proposed Line 3 tar sands pipeline by demanding an official seat at the decision-making table.

The State of Minnesota just released their draft Environmental Impact Statement on Line 3, and it’s a good start—but not good enough. The climate analysis is not nearly as robust as it needs to be to give the Youth Climate Intervenors a chance to win their case.

These 13 young people are all under 25. They are representing themselves, without a lawyer, because they know they are the best advocates for their own futures. They are taking on the biggest oil pipeline company in North America, and pioneering a legal argument that has never been tried in pipeline resistance.

Minnesota youth are taking a bold stance to hold the fossil fuel industry accountable for their futures—and they need to have the best information available to make their case. Add your name today to make sure the environmental review exposes Line 3 as the climate catastrophe it really is.

(We encourage you to add your own personal comments as well—the more different voices and stories the Minnesota Department of Commerce hears speaking up against this pipeline, the more they will pay attention!)

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To: Minnesota Department of Commerce
From: [Your Name]

The Line 3 Draft Environmental Impact Statement is a step in the right direction for assessing oil pipeline projects in Minnesota, but contains multiple glaring errors and deficiencies. Keeping in mind the young people of Minnesota - and those across the country, and the globe - we respectfully submit the following critiques:

I. The inclusion of a comprehensive social cost of carbon is absolutely essential, but even the staggering prediction of up to $287 billion (Chapter 5, page 433) only utilizes a 30 year scope. Page 6 of the Project Summary in Chapter 2, states “The Applicant anticipates that the physical life of the Line 3 Replacement pipeline (i.e., the number of years that the pipeline would be capable of transporting crude oil) would be indefinite given appropriate construction, maintenance, and integrity systems. The economic life of the Project (i.e., the number of years that continued operation of the Project would be feasible) is anticipated to be no less than 30 years,” (emphasis added). It is illogical and irresponsible to use a timeframe that Enbridge and the DEIS itself admit to be the bare minimum potential lifetime and impact of the Project. The current Line 3 is more than 60 years old, and Enbridge claims to have improved their technology and building practices, making a 30 year scope is drastically inadequate. Furthermore, the climate impacts being examined will continue well beyond the operating life of the physical pipeline, and should be analyzed with that scientific reality in mind. A minimum 60 year timeline for the direct pipeline impacts and 100 year timeline for the indirect climate impacts should be the absolute minimum acceptable scope.

II. Chapter 5, page 435, states that “Construction along the Applicant’s preferred route could require the removal of trees from up to 1,682 acres of forested land in the construction work area. Of this, 702 acres would remain permanently without trees, while the forest would be allowed to regrow on the other 981 acres….Consequently, the amount of carbon that potentially would be released back into the atmosphere during construction tree removal of 1,682 acres is estimated at approximately 205,500 tons of CO2e. Regrowth of the forest on the 981 acres outside of the pipeline right-of-way eventually would more than halve this loss in the long run after forest regrowth, bringing net CO2 emissions from forest clearance down to a level of about 85,658 tons.” The “Methods for Calculating Forest Ecosystem and Harvested Carbon with Standard Estimates for Forest Types of the United States” paper by Smith et. al. from which the carbon release numbers are derived uses data from trees ranging in age from zero years to 125 years of age. Full sequestration of the 119,842 tons of CO2e associated with the 981 acres of reforestation can therefore not be expected to be fully complete until the year 2143, assuming the deforestation occurs in 2018. Given the prevailing scientific conclusion that greenhouse gas emissions need to be significantly curbed over the next 5-10 years to avoid initiating catastrophic feedback loops, it is unrealistic and scientifically unsound to equate sequestration taking place over 125 years with mitigation of the CO2e release in the year 2018. The associated climate impacts will have taken place long before the sequestration is complete, and delayed absorption of CO2 will not remediate the significant alterations to the earth’s climate (and the planet’s ability to support its current ecosystems) brought about as a result of exacerbated feedback loops. Therefore, these calculations and the assumed net CO2 emissions from forest clearance should be revised.

III. The Executive Summary states on page 19 that the “primary impacts of climate change on the Project include severe weather, freeze-thaw cycles, and flooding, all of which could damage project facilities.” Climate impacts are projected to worsen over the course of the next 80 years, increasing the likelihood that these damages to the Project occur during the lifetimes of Minnesota’s current youngest generation. The increased likelihood of a spill or decrease in the Project’s structural integrity due to climate impacts should be included in the projected likelihood of accidental product release events, and identified as such, on a timeline of a minimum of 60 years (a benchmark consistent with the lifetime of the current Line 3).

IV. There is no serious consideration of a no-build option. The Executive Summary specifically states on page 17 that “all GHG emissions contribute to cumulative climate change, so all of the alternatives would play a role in global climate change,” (emphasis added). This clearly ignores any no-build alternative. The Environmental Impact Statement is not meant to analyze the necessity of the Project, but instead to prepare all relevant data so that the need (or lack thereof) can be adequately examined during the Certificate of Need process. Therefore, the DEIS is incomplete without a serious examination of a scenario in which the current Line 3 is decommissioned and not replaced. This option has been advocated for by thousands of Minnesotan citizens, is realistic with projected economic modeling around reducing oil dependency and increasing electrification and alternative energy, and clearly deserves serious consideration and study. It is also the most consistent with Minnesota’s commitment to upholding the Paris Agreement, and leading on climate action.

V. The overall workmanship of the draft Environmental Impact Statement is flawed and indicative of only a cursory level of dedication to the analysis. The serious and long-lasting impacts this Project will have on Minnesota’s youngest generation deserve a more thorough and respectful review than this document conveys. First, nine of the citation links in Chapters 9, 10, 11, and 12 are broken or inaccessible without site login information. This makes the source material for the DEIS both questionable in authenticity, and inaccessible for public review. Second, the listed alternatives in Chapter 4 involving rail and truck transportation are inconsistent with standard methods in the industry, and wholly infeasible and illogical. Beyond the overall absurdity of these proposals, page 13 of Chapter 4 uses the same volume of product that would transported by pipeline in the calculations for transportation by rail, without discussing the removal of diluent that would only be needed to increase the viscosity of the oil in a pipeline, not a rail car. This could significantly change the volume of product to be moved in a rail scenario, so these numbers should be revisited. Finally, Tribal Resources and Environmental Justice chapters (Ch. 9 and Ch. 11, respectively) lack depth, do not sufficiently cross-reference one another, and are offensively incomplete in their analysis of structural societal impacts such as the increase in sex trafficking associated with similar projects (page 10, Chapter 11).

VI. This draft Environmental Impact Statement is inadequate without serious consideration given to the eventual retirement and removal of the Line 3 Replacement. There is no sunset clause or removal plan referenced in this document whatsoever. As previously cited, page 6 of the Project Summary in Chapter 2, states “The Applicant anticipates that the physical life of the Line 3 Replacement pipeline (i.e., the number of years that the pipeline would be capable of transporting crude oil) would be indefinite given appropriate construction, maintenance, and integrity systems.” An indefinite life expectancy is shorthand for a lack of research and attention given to obvious fact that the pipeline will eventually become inoperable, obsolete, or prohibitively damaged, and need to be retired. Especially given the level of concern being raised about the current Line 3 and the lack of planning that led to it being cited close enough to other lines to make its removal difficult, forethought about clean-up measures is clearly needed from the beginning of a project.

In conclusion, we appreciate the requirement of an Environmental Impact Statement for crude oil pipeline projects in the State of Minnesota, and believe that this DEIS should set a more diligent precedent for these kinds of analyses. The current DEIS is inadequate because it disregards its own parameters for a realistic scope, contains miscalculations in regards to carbon sequestration from land reforested after construction, does not account for the increased risk of accidental product release as a result of climate-change-induced stress on the Project, neglects to fully analyze all reasonable alternatives by ignoring a no-build scenario, displays poor workmanship and multiple simple data errors, and omits any consideration of the eventual retirement of the Line 3 Replacement. Only a comprehensive DEIS that addresses these concerns will be adequately complete and support an informed decision on the future of Minnesota’s infrastructure and natural resources.