Immediate Action Needed: Enbridge Energy has filed a Certificate of Need permit with the Minnesota Public Utilities Commission to increase the capacity of its Line 67 pipeline by 26%. The PUC accepted public comments and Enbridge made a response. The PUC is now accepting rebuttal comments from the public UNTIL MAY 3.

Please review the information below and send your comments to: PublicComments.PUC@state.mn.us. Comments ARE public and are available online.

Background: Enbridge Energy extracts and exports oil from Canada. (You can learn more about Enbridge, its pipelines and some safety concerns here and here.) It has more than five pipelines crossing northern Minnesota, including Line 2 (in the news recently because of an oil spill (see the De Smog Blog to learn more)), and Line 67, which carries diluted bitumen (DilBit/ tar sands oil). This is the first of its planned capacity increases to Line 67, although it is not currently operating at full capacity.

In its response to public comment, Enbridge has acknowledged the risks posed by oil and gas pipelines, including accidental oil and gas spills and air pollution. They have said that the pipelines “emit air pollutants as would any other machine.”

Those wishing to make rebuttal comments may want to highlight the actual impact of oil spills by pointing out the health impacts of (Exxon’s) Mayflower, AK, oil spill, and Enbridge’s responsibility for the 2010 pipeline rupture near Marshall, Michigan that resulted in 850,000 gallons of crude oil being spilled into the Kalmazoo river, which is still not cleaned up.  The National Transportation Safety Board issued a highly critical report on Enbridge as a result of that pipeline rupture.

Furthermore, while the pipeline itself may have limited emissions, the dirty oil it carries will have life-threatening consequences when it is burned. This oil is intended for foreign markets that have even fewer environmental precautions than the US and Canada.

Enbridge’s Convenient Climate Math

Enbridge submitted this statement, from Docket 12-590 Document 9: Draft Supplemental Environmental Impact Statement (provided by researcher Kathy Hollander.)

“Worldwide demand for crude oil is generally projected to grow over the next 25 years unless countries, including developing economies where the majority of the growth is projected to occur, take substantial steps to address climate change. But even if there is a worldwide decline in crude oil consumption, projections indicate that there will be an increase in consumption of crude oil from unconventional sources, primarily from the Canadian oil sands, over the next several decades (EIA 20 12; IEA 20.12)

“… Differences in oil sands production between … different scenarios give an indication of how substantial changes in worldwide policies and energy could impact oil sands production:

• The Current Policies Scenario, which assumed no change from policies in place in mid-2010,
• New Policies Scenario, which assumed that countries act on their announced policy commitments and plans to address climate change; and the
• 450 Scenario, which sets out an energy pathway with the goal of limiting the global increase in temperature to 2°C by limiting concentration of greenhouse gases in the atmosphere to around 450 parts per million of carbon dioxide, 3.4 million barrels per day production.

“Although the different scenarios had substantial impacts on projections of total oil sands production in 2035, the projected consumption in each of these scenarios represents a substantial increase from 2011 consumption of approximately 1.6 million bpd (barrels per day) of oil-sands-derived crude oil (CAPP 2012).”

Never heard of these various Scenarios? Learn more here, here and here.

We more commonly hear about a carbon goal of 350 parts per million (ppm). That is the goal that leading climate scientists have agreed is the safe upper limit to avoid irreversible, runaway climate change. 450 ppm is the “goal” set in 2010 at the UN Framework Convention on Climate Change. That is the level of carbon they imagined we could reach while still giving ourselves a 50-50 chance of stabilizing the climate at a 2º increase in temp.

Here’s what 350.org has to say about that number 450.

“Science doesn’t actually know if 450 ppm and 2 degrees are the same thing, and no one knows how much change they would produce. Again, these were guesses for the point at which catastrophic damage would begin—they were more plausible, but still not based on actual experience. They also reflected guesses of what was politically possible to achieve. They were completely defensible, given the lack of data…

In the summer of 2007, though, with the rapid melt of Arctic ice, it became clear that we had already crossed serious thresholds. A number of other signs pointed in the same direction: the spike in methane emissions, likely from thawing permafrost; the melt of high-altitude glacier systems and perennial snowpack in Asia, Europe, South America and North America; the rapid and unexpected acidification of seawater. All of these implied the same thing: wherever the red line for danger was, we were already past it, even though the atmospheric concentration of CO2 was only 390 parts per million, and the temperature increase still a shade below 1 degree C.

“In early 2008, Jim Hansen and a team of researchers gave us a new number, verified for the first time by real-time observation (and also by reams of new paleo-climatic data). They said that 350 parts per million CO2 was the upper limit if we wished to have a planet “similar to the one on which civilization developed and to which life on earth is adapted.” That number is unrefuted; indeed, a constant flow of additional evidence supports it from many directions. Just this week, for instance, oceanographers reported that long-term atmospheric levels above 360 ppm would doom coral reefs worldwide.

“It is, therefore, no longer possible to defend higher targets as a bulwark against catastrophic change. The Global Humanitarian Forum reported recently that climate change was already claiming 300,000 lives per year—that should qualify as catastrophic. A new Oxfam report makes very clear the degree of suffering caused by the warming we’ve already seen, and adds “Warming of 2 degrees C entails a devastating future for at least 600 million people,” almost all of them innocent of any role in causing this trouble. If the Arctic melts at less than one degree, then two degrees can’t be a real target. This is simply how science works. New information drives out the old.

“You could, logically, defend targets like 450 or 2 degrees C as the best we could hope for politically, especially if you add that they represent absolute upper limits that we must bounce back below as quickly as possible. But even that is politically problematic, because it implies—to policy makers and the general public—that we still have atmosphere left in which to put more carbon, and time to gradually adjust policies. We don’t—not with feedback loops like methane release starting to kick in with a vengeance.”

The Enbridge pipeline is dangerous. It is dangerous in its transport of a highly toxic product and it is dangerous in the effect that its product will have on our atmosphere. Please take time today, tomorrow or Friday to write a rebuttal.