Great Lakes Group: State Advisory Board Must Recognize Urgency, Consider Line 5 Oil Pipeline’s Impact to Inland Waterways and Climate Change
TRAVERSE CITY – Great Lakes law and policy center FLOW submitted additional comments today to the Michigan Pipeline Safety Advisory Board in response to its requests for information and proposals to conduct alternatives and risk analyses for the Line 5 oil pipelines in the Mackinac Straits. The group expressed deep concern about the Advisory Board’s lack of urgency addressing the potential for a catastrophic oil spill in the Straits, failure to consider Line 5’s climate change impacts, and the pipeline’s additional threat to inland waterways that feed the Great Lakes. In response to criticism from concerned groups and citizens about the narrow 5-day comment period, the Advisory Board extended its public comment period to February 16, 2016.
One of the group’s key concerns is the unclear process by which the Advisory Board plans to integrate the two separate risk and alternatives analyses reports. “This is a critically important step because the level of acceptable risk that is determined in the risk analysis will inform which alternative will ultimately be selected by the state,” said FLOW Executive Director Liz Kirkwood. “This correlation is essential to this process and must be understood by the contractors and the public.” Another key issue is the lack of a sense of urgency by the Advisory Board and the entire process as a whole, as evidenced by the lack of any timeline for the review and reporting stage. “At this time, it appears the current process will run into 2017 and there are no expectations for interim or conclusive measures in the meantime,” Kirkwood said. A third recommendation is to create one central website accessible to the public that includes all of the Advisory Board’s findings, reports, and opinions as well as all public comments, testimony, and reports related to Line 5. The group also is calling for more transparency and public comment opportunities on the risk and alternatives analyses reports.
The group’s most substantive remark is the need to recognize climate change and how it impacts our understanding of both the risk and alternatives analyses, given national and global commitments to keep average temperatures below 1.5 degrees Celsius. Accordingly, FLOW contends that contractors must assess each alternative’s role in contributing to carbon emissions by examining its fossil fuel emissions, economic viability in a rapidly changing global energy market, and externalized social and environmental costs. Line 5 is a part of a larger Enbridge network that makes up the world’s largest pipeline system carrying the planet’s dirtiest and most energy-intensive oil – light crude derived Canadian tar sands. In addition, vulnerable inland sections of Line 5 must be examined as part of the overall analysis.
FLOW submitted separate comments to the Advisory Board last week, before the public comment period was extended. These recommendations included the call for a public peer review of both reports, the importance of defining a broad range system that identifies and reviews the economic impacts to the Great Lakes, and the inclusion of credible worst-case scenarios instead of the antiquated regulations defined by the Dept. of Transportation. Additional recommendations were to include alternative release and worst-case scenarios in the risk analysis and to address public health impacts on drinking water and air emissions.
View Full Comments: 2/4/16 and 2/12/16 at flowforwater.org.
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