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Council of Canadians submission to OEB on Energy East

The Ontario Energy Board has been collecting comments as part of its ongoing Energy East Consultation. The Council of Canadians has added a formal submission outlining why this pipeline is all risk and little reward for Ontario.  You can read the full submission.

For a sneak peak, here are some highlights:

Energy East – an export pipeline

Greater energy independence in Eastern Canada and strengthening the region’s refinery sector has been suggested as important benefits of the Energy East pipeline project.[i] But Energy East is not about meeting Ontario’s oil needs. It is also not about supplying Eastern Canada’s oil needs. The pipeline will be used first and foremost to export oil – unrefined – from two new ports in Quebec and New Brunswick.

The unacceptable risk of a diluted bitumen spill in Ontario waterways

A pipeline spill could pollute many important waterways and drinking water sources such as Trout Lake, Lake Nipissing, the Nipigon river system (which could contaminate Lake Superior) and the Rideau River. The remoteness of much of the pipeline’s path in Northern Ontario will make detecting and cleaning up a spill much more difficult.

More needs to be understood about the location of the pipeline on top of aquifers and the potential for contamination. For example, just outside of Ottawa, the pipeline crosses the Oxford aquifer, which supplies drinking water for more than 10,000 people in North Grenville.[ii] This aquifer has been labelled as highly vulnerable to contamination by the Ontario government …

Despite the evidence of the unique consequences of a dilbit spill, related outstanding questions, and the difficulties with dilbit spill cleanup, the NEB does not have separate and specific regulations for transporting dilbit…

Astoundingly, TransCanada denies that dilbit sinks in water, referring to this statement as a “myth” in promotional material.[iii] This strongly suggests that the unique and environmentally devastating challenges of a dilbit spill are not being factored into the emergency response plans TransCanada is coordinating in preparation of filing its full application for the Energy East pipeline with the NEB.

Pipeline safety?

 Between 1991 and 2013 there were eight incidents in [TransCanada’s Mainline system] this series of pipelines including ruptures, explosions and fires. These incidents, which were largely the result of stress corrosion cracking, external corrosion, coating and welding failures, raise concerns about the safety of aging pipeline infrastructure.[iv] The 100-4 pipeline, which is slated for conversion, ruptured because of external stress corrosion cracking near Rapid City Manitoba in July 1995. The delayed response in shutting down the pipeline led to a second fire on a nearby pipeline – Line 100-3.[v] In most of these ruptures, it was the general public or TransCanada personnel that alerted TransCanada that the incident had occurred, not leak detection systems.

Climate implications of Energy East must be recognized

The Energy East pipeline threatens to undo [Ontario’s]progress. Preliminary analysis from Pembina Institute indicates the crude production needed to fill the Energy East pipeline would generate an additional 30 to 32 million tonnes of carbon emissions each year.[vi] This is the equivalent of adding more than seven million cars to Canada’s roads. It is enough pollution to wipe out the emission reductions from Ontario’s phase-out of coal.[vii]

Ontario becoming more reliant on fracked gas imports

 [expert evidence brought forward on behalf of the Council of Canadians to the OEB previously highlights impacts of greater reliance on fracked gas to includes] Geoscientist David Hughes’ evidence that fracked gas in the Marcellus shale is unlikely to be as abundant and inexpensive as commonly assumed.[viii] It includes environmental consultant Lisa Sumi’s summary of the myriad of regulations in play to address the significant environmental footprint of producing fracked gas in the Marcellus shale. These regulations will have consequences for both the cost and availability of the gas.[ix] We also highlighted Anthony R. Ingraffea’s research indicating that the “footprint for shale gas is greater than that for conventional gas or oil and for coal used for electricity generation when viewed on any time horizon, but particularly so over 20 years.” Ingraffea is a professor of engineering at Cornell University.[x]

Provincial leadership required 

Canada does not have a national strategy to address urgent water issues or an effective climate policy. There is no federal leadership to conserve and protect our water or a plan to ensure Canadians have access to the energy we need, while reducing our fossil fuel dependency. During a time of global water and climate crises, the federal water policy is 27 years old and badly outdated. There is yet to be any federal regulation of emissions of the oil and gas sector…

…It is in this context that provincial leadership is needed, now more than ever. Leadership that rejects projects like Energy East, which will send Canada further down the path of risking important waterways, fostering further expansion in the tar sands, and more climate emissions.

We commend the Energy Minister’s commitment to represent Ontario’s interests before the NEB, as well as the comprehensive consultation being undertaken by the OEB. Ultimately, we feel the scale of imminent threat presented by the Energy East pipeline, and the abdication of the Harper government of its duties, justifies Ontario’s intervention based on these unacceptable risks. In order to represent Ontarians’ interests, the Premier should speak publicly against the Energy East pipeline.

[i] TransCanada Corporation. “The Benefits of the Energy East Pipeline.” <http://www.energyeastpipeline.com/benefits/the-benefits/>

[ii] http://www.mrsourcewater.ca/assessment_report/chapter9/MRSPR_HVAs.pdf

[iii] TransCanada Corporation. “Pipeline Particulars: About the Energy East Project.” Community Link. 2.1. <http://www.energyeastpipeline.com/wp-content/uploads/2014/03/Energy-East-Community-Link-Vol-2-Issue-1.pdf>

[iv] Transportation Safety Board of Canada. Pipeline Investigation Reports. <http://www.tsb.gc.ca/eng/rapports-reports/pipeline/index.asp>

[v] Transportation Safety Board of Canada. Pipeline Investigation Report P95H0036. <http://www.tsb.gc.ca/eng/rapports-reports/pipeline/1995/p95h0036/p95h0036.asp>

[vi] Demerse, Clare and Erin Flanagan. “Climate Implications of the Proposed Energy East Pipeline, A Preliminary Assessment.” Pembina Institute. 6 Feb. 2014. <http://www.pembina.org/pub/2519>

[vii] Ibid.

[viii] Hughes, J. David. Shale Gas Supply to the Greater Toronto Area. <http://canadians.org/sites/default/files/publications/OEB%20Hughes.pdf>

[ix] Sumi, Lisa. The Regulation of Shale Gas Development: State of Play. 28 Jun. 2013. <http://canadians.org/sites/default/files/publications/OEB%20Sumi.pdf>

[x] Ingraffea, Anthony R. The Carbon Footprint of Shale Gas Development and the Remedial Measures Necessary to Address it. 26 Jun. 2013. <http://canadians.org/sites/default/files/publications/OEB%20Ingraffea.pdf>