WAPOA’s Position on Pipeline

Enbridge, a Canadian company, is proposing to put a new 30-inch crude oil pipeline across land in the Pine River Watershed north of the Whitefish Chain.  The pipeline would cross four rivers that flow into the Whitefish Chain.

Ed.Note 9-3-2016:  Enbridge has withdrawn its request for the Sandpiper pipeline.  However, it wants to continue with an even larger (36 inch) pipeline (called Line 3) along the route Sandpiper was to take.  So the problem is the same, a pipeline crossing at least 4 of the streams that eventually find their way to the Whitefish Chain.

The following is a note from Tom Watson, WAPOA President, explaining WAPOA’s position.


 

The Board of Directors of the Whitefish Area Property Owners Association (WAPOA) submitted comments Friday, January 23, 2015 on the Certificate of Need (CON) for the proposed Sandpiper Pipeline submitted by Enbridge Energy Limited Partnership and North Dakota Pipeline Company LLC. 

A copy of our letter is included under Enbridge on this webpage. 

WAPOA has viewed this Project has having predictable potential for “significant environmental effects” with the proposed route, which should be carefully and thoughtfully considered during the CON process by the Administrative Law Judge and the MNPUC (Minnesota Public Utilities Commission). 

The impact on the Whitefish Chain of Lakes and the Pine River Watershed are identified by Enbridge in its submitted materials.

  WAPOA believes the “lake country” of north central Minnesota needs to be fully protected from oil pipelines construction and operations because of the history of Enbridge’s pipeline breaches that are “real threats” to the public waters, plants, forests, and wildlife in this area. 

WAPOA is not opposed to pipelines being constructed and operated for the transport of crude oil. 

We fundamentally believe that the approved route must be one that avoids the “real threats” to the acres of surface and ground water in this area and the “lake country” of north central Minnesota. 

We have also included, at this time, the letters submitted by the MN Pollution Control Agency (MPCA) and the MN Department of Natural Resources (DNR), along with a map showing the Enbridge proposed route and the recommended alternate routes of the MPCA and DNR.

If you have questions about the WAPOA position, please contact us or me.

Tom Watson, President


 BELOW WAPOA’S LETTER TO THE MINNESOTA PUBLIC UTILITIES COMMISSION

January 23, 2015

Burl Haar
Executive Secretary
Minnesota Public Utilities Commission
121 7th Place East, Suite 350
St. Paul, MN 55101-2147
Re:  PUC Docket Number  PL-6668/CN-13-473

Dear Mr. Haar:

The Board of Directors of the Whitefish Area Property Owners Association (WAPOA) is appreciative of this opportunity to comment on the Certificate of Need (CON) for the proposed Sandpiper Pipeline submitted by Enbridge Energy Limited Partnership and North Dakota Pipeline Company LLC (collectively, Enbridge/NDPC) as described in the above referenced Docket Number.

The Whitefish Area Property Owners Association (WAPOA) is a 45 year old 501(c)(3) non-profit entity representing the 14 lakes comprising the Whitefish Chain of Lakes in northern Crow Wing County.  We have a membership of over 1,100 private property owners and about 65 area businesses.  The eighth (8th) largest lake system in Minnesota, the Whitefish Chain of Lakes covers 14,400 acres of open water, 119 miles of shoreline and a catchment area of nearly 30,000 acres in northern Crow Wing and south and southeastern Cass Counties.

As Enbridge acknowledges in their application and related materials, the proposed Sandpiper Pipeline and route would directly impact the Whitefish Chain of Lakes and the larger catchment area.  The greater Whitefish Chain of Lakes area is a major tourism area in Minnesota and drives the economy of the area.  The proposed Sandpiper Pipeline is a serious environmental matter for the property and business owners of the Whitefish Chain of Lakes area and the larger Pine River Watershed through which Enbridge/NDPC has proposed to locate the Sandpiper Pipeline.

By a unanimous vote, WAPOA’s Board of Directors approved this letter and our request of the Minnesota Public Utilities Commission (PUC) regarding the Enbridge/NDPC application and the consideration of the system alternatives as described in the files for the above referenced Docket Numbers:

    1.    Is the proposed project needed and in the public interest?
The WAPOA membership and Directors clearly understand the need for a pipeline to transport crude oil from North Dakota and the Canadian provinces to market. This has never been an issue, even though the Enbridge campaign would lead one to believe otherwise.
Second, the proposed pipeline will NOT replace trains and trucks in transporting this crude oil.  Rather we understand that the proposed pipeline is needed to serve an increasing demand for crude oil transport, provide a safer mode of transportation, and relieve trucks and trains to some degree.  The testimony in this case indicates that sixty (60) percent of the crude oil will continue to be transported by rail and truck even after the proposed pipeline was operational.  In other words, the proposed pipeline, along with continued use of trains and trucks, will transport the projected increasing crude oil produced in these two areas.  This means there is not only a greater need to transport crude oil, but also a greater need to carefully and thoroughly consider the public interest in terms of the environmental impact too.
Last, the CON must consider the market for North Dakota and Canadian crude oil.  At the present time, the production is being curtailed and reduced as a result of the decrease in the price for a barrel of crude oil.
The argument presented by many that this crude will lessen the United States market demand for foreign crude oil is illusory.  As presented by Enbridge, there primary market for this crude oil is not the United States, but rather foreign markets.

    2.    What are the costs and benefits of the proposed project?
WAPOA opines that the critical issue in this proposed pipeline project is the cost-benefit analysis of this project.  In addition to all the employment and suppliers who have direct benefit as a part of and during construction, we encourage the consideration of the two additional economic facts:
    Economic impact of the tourism industry on the local and state economy; and
    Environmental affects and disclosures on the public waters in the North Central area of Minnesota.

Economic impact of the tourism industry on the local and state economy.
Enbridge/NDPC has presented the economic value of this pipeline both for the petroleum company involved and its industry, and the construction trades and employment.  We fully understand and appreciate those facts.
Our area of north central Minnesota, as noted, is composed of a large amount of surface water in the form of lakes, rivers, creeks and wetlands.  Crow Wing County is composed of 28 percent – or 209,211 acres – of the County by lakes, streams and wetlands.  The northern portion of Crow Wing County we represent comprises a large portion of those “water-based” acres at fifteen (15) percent or 30,000 acres.
Water is the key element for the tourism industry of this area year-round, but especially in the summer season.  Tourism spending in Crow Wing County is the third largest outside of the Twin Cities metropolitan seven county area after only Olmstead and St. Louis Counties.
How large is this tourism impact on the local economy?  Very large in direct tourism (leisure and hospitality as defined by the State of Minnesota Departments of Revenue and Employment and Economic Development) spending in Crow Wing, Cass and Hubbard Counties, as shown below for calendar year 2012 gross sales, sales tax revenue and employment:
                                             2012  Gross Sales                Sales Tax Rev      Employment
Crow Wing County            $201,073,526                        $12,686,611             3,892
Aitkin County                      $20,692,436                           $1,425,354                497
Cass County                        $102,411,781                          $6,196,420             1,736
Hubbard County                  $29,955,194                           $2,018,357                741
Total                                      $354,132,937                           $22,326,742            6,866
A tourist or visitor in this data is a person whose primary residence is more than 50 miles from the border of a county.
WAPOA is firmly advocating that the Minnesota Public Utilities Commission (PUC) strongly consider the “negative” and adverse economic impact on the local tourism economy in our area of pipeline spills, fires and breaches along the proposed Enbridge/NDPC Sandpiper Pipeline.  Although unrelated to a pipeline issue, the negative economic impact of the recent fishing decisions on Mille Lacs Lake is a very good indicator of the sensitivity of the tourism industry to industry factors, government decisions, adverse factors, and timing.
Enbridge/NDPC has noted the construction employment involved (reported by Enbridge/NDPC at about 1,500 jobs) in constructing their proposed pipeline as a positive for their proposal.  Enbridge/NDPC has not only failed to represent that this employment is short-term and, but not sustainable local employment, but also failed to address the adverse impact on the local economy, largely dependent on tourism and “water quality” of the inevitable constructed pipeline spills and breaches.  As shown in the table above, the annual tourism industry direct employment is four (4) times the short-term Enbridge/NDPC construction employment.
The PUC should clearly consider the tourism economic impacts and measures in considering in this certificate of need matter.

Environmental effects and disclosures on the public waters in the North Central area of Minnesota.

As we understand, the state regulatory agency(ies) has a provision for completing a comparative environmental analysis of the Enbridge/NDPC proposed pipeline route, along with all accepted system alternative routes.  WAPOA is fully supportive and encourages the PUC to require these environmental analyses to be completed before any PUC decisions are made.

WAPOA cannot imagine a project that has more potential for “significant environmental effects” than this Project.  The lakes of and about the Whitefish Chain of Lakes and the Pine River Watershed, which are some of the clearest and cleanest in Minnesota, along with the area rivers, creeks, and wetlands are all extremely vulnerable to adverse impacts from construction, leaks and spills from this Pipeline.  Our water resources, including both surface and ground water, are extremely vulnerable to these adverse impacts and threats from construction and spills.  Actual incidents that are highly predictable could be devastating to these public waters.  The forests, lands and wildlife in the area of the proposed Pipeline are also vulnerable to adverse impacts that should be analyzed thoroughly.
WAPOA has a major concern about safety.  We know that pipeline spills, leaks, fires and other pipeline breaches have occurred, both in Enbridge operations (over 800 in ten years); recently in Montana.  While we have reviewed most materials submitted by Enbridge/ NDPC, we believe strongly that proposed prevention and safety measures for protecting our wetlands, rivers, lakes and environmentally sensitive lands and areas from the construction and operation of the proposed Sandpiper Pipeline must be factored in the economics of this proposal.
 3.    What are the environmental and human impacts of the proposed project and how can these impacts be addressed?
Addressed above.

 4.    Do any of the factors listed in Minnesota Rule 7853.0130 have particular importance in this 
case? https://www.revisor.mn.gov/rules/?id=7853.0130

    5.    Are there other project-related issues or concerns?
The Sandpiper proposal of Enbridge/NDPC, as well as the proposed eight (8) system alternates, should be subject to the comparative environmental analysis.  The “lake country” of north central Minnesota needs to be fully protected from oil pipelines construction and operations because of the history of Enbridge’s pipeline breaches that are “real threats” to the public waters, plants, forests, and wildlife in this area.

We view this Project has having predictable potential for “significant environmental effects” with the proposed route, which should be carefully and thoughtfully considered during the CON process by the Administrative Lawe Judge and the MNPUC.

Thank you for considering our requests.  If you have any questions or want to discuss our request, please call Tom Watson, WAPOA President at 218-543-6064.

Sincerely,
Whitefish Area Property Owners Association (WAPOA)

Thomas N. Watson

Thomas N. Watson
President