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Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 DRAFT – Not for Public Release Enbridge Sandpiper EIS Scoping White Paper The Wisconsin Department of Natural Resources held a Public Scoping Meeting regarding the proposed Enbridge Sandpiper new Line 3 project, and the proposal to triple the capacity of the existing Line 61. The meeting was held August 26, in Superior, Wisconsin. This document has been researched and developed as a draft in order to provide information to address public questions, comments and concerns provided at the scoping meeting and received by WDNR through the end of the public comment period (October 1, 2014). EIS Overall C - Produce a comprehensive EIS using due diligence and a transparent process. R – DNR staff intend to evaluate all public concerns as they develop an EIS. The process required under NR 150 allows for public review and comment (and quasi-judicial challenge?). The proposed project will be defined according to information the applicant has provided on their permit application. C- Proceed with the EIS guided by the “Precautionary Principle,” recognizing the need to proceed more slowly in light of inadequate data. R – WDNR will make all reasonable attempts to obtain data we feel is necessary to fully analyze a proposed action. By administrative rule, we are required to identify in an EIS those areas where data that is important to evaluating environmental impacts is unavailable or incomplete. We also will include a description of the relevance of any unavailable or incomplete information. The lack of data would not necessarily require slowing the process of developing an EIS. C - You need a joint state (MN/WI)-federal EIS, in order to achieve a global scale outlook. Use the U.S. EPA Bristol Bay Mine EIS as a model. R – WDNR administrators have contacted the U.S. Army Corps of Engineers and have concluded that the time frame for developing a federal EIS would most likely be incompatible with that of developing a state EIS. WDNR has also been in contact with MDNR staff who are evaluating the Minnesota portion of these pipeline projects, and are awaiting a decision regarding a possible change in the proposed route through Minnesota. Flammability of pipeline products C - Look at the two related lines separately due to the differences between the products they are designed to carry: tar sands crude with volatile diluent, and Bakken shale oil with natural gas liquids that makes it more flammable. R – It is possible that either of these two pipelines could carry either of those two energy products, so we intend to evaluate both lines in terms of potential impacts with either material. Bakken Crude: Tests have shown that Bakken crude is indeed more flammable that other crudes. The flash point or lowest temperature at which a flammable liquid gives off sufficient vapor to form an ignitable mixture with air near its surface or within a vessel is lower for Bakken oil than it is for tar sands oil coming out of Canada. That fact led the DOT to issue a Bakken Shale Oil Shipping Safety Alert January 3, 2014: “The Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a safety alert for Bakken crude [a part of its “Operation Classification” program to check oil shipments to see whether the oil being shipped by rail is correctly analyzed and classified regarding its hazard potential]. PHMSA issued the alert to reinforce the need to test, characterize, classify, and where appropriate de-gassify the crude oil before transportation. PHMSA has reminded first responders of that light sweet crude is assigned a packing group of I or II. Those packing groups mean the flash point is below 73 degrees Fahrenheit and the boiling point for packing group II is below 95 degrees Fahrenheit. “Operation Classification” will be an ongoing effort, and PHMSA says it will continue to collect samples and measure the characteristics of Bakken crude as well as oil from other locations. Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 The oil industry reportedly acknowledges that “additional safety measures need to be taken when hydrogen sulfide or other flammable gases are dissolved in the oil. The oil needs to be degasified before transportation” (Bakken Shale News – http://bakkenshale.com/news/bakken-oil-flammable/). PHMSA expects to have final test results in the near future for the gas content, corrosivity, toxicity, flammability and certain other characteristics of the Bakken crude oil, which should enable the proper characterization of the material (PHMSA 2014). http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/? vgnextoid=c6efec1c60f23410VgnVCM100000d2c97898RCRD&vgnextchannel=d248724dd7d6c010VgnVCM 10000080e8a8c0RCRD&vgnextfmt=print). The North Dakota Petroleum Council in 2014 reported on an analysis conducted by an engineering consultant regardingBakken Q theuali characteristicsty Characteriz aofti oBakkenn crude oil. Their results are as follows:

• Bakken crude is a light sweet crude oil with an API gravity generally between 40° and 43° and a sulfur content <0.2 wt.%. As such, it is similar to many other light sweet crude oils produced and transported in the United States.

o As a point of reference, the Energy Information Administration (EIA) categorizes crude oil that has an API gravity between 35° and 50° and less than 0.3 wt% sulfur as light sweet. Bakken falls in the middle of those ranges for both properties.

• Although testing for sulfur, Total Acid Number (TAN) and other corrosivity-specific testing were outside the scope of this project. Results from other test programs, as summarized below in Table 1, indicate that Bakken has very low sulfur and TAN properties.

• Table 1 compares key Bakken qualities to other important domestic and international crude oils: o Note the quality data in Table 1 for crudes other than Bakken came from sources without the extensive controls and systematic sampling procedures used in the NDPC study. Table 1: Comparison of Crude Properties

Domestic Light Sweet Crudes API Gravity Sulfur (wt. %) TAN (mg KOH) Bakken (1) (2) 40 to 43* 0.1 < 0.1 WTI (4) (5) 37-42 0.42 0.28 LLS (2) (4) 36-40 0.39 0.4 Eagle Ford (2) 47.7 0.1 0.03 Eagle Ford Light (2) 58.8 0.04 0.02

International Crudes API Gravity Sulfur (wt. %) TAN (mg KOH) Light Sweet Brent (2) (6) 37-39 0.4 < 0.05 Medium Arabian Light (2) 33 1.98 < 0.1 Arabian Heavy (2) 27.7 2.99 < 0.1 Heavy 2 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Western Canadian Select (Heavy Sour) 21.3 3.46 0.93 Dalia (High TAN) (2) (7) 23.1 0.51 1.6

 Source – North Dakota Petroleum Council, 2014.

Sources [used by NDPC survey]: 1 - NDPC Study Data 5 - Crude Oil Quality Association 2 – Capline 6 - BP Crude Assay 3 - crudemonitor.ca 7 - ExxonMobil Crude Assay 4 - AFPM Bakken Report, 5/14/2014 * Majority of NDPC samples in this range

• The qualities of Bakken were very consistent within our sample population and throughout the supply chain – from wellhead to rail terminal to refining destination. Test results showed no evidence of “spiking” with Natural Gas Liquids (NGLs) before rail shipment.

• The test results from this study are also consistent with reported results from others, including the American Fuel & Petrochemical Manufacturers (AFPM) Bakken Report, the Pipeline and Hazardous Safety Materials Administration (PHMSA) Operation Safe Delivery Report, NDPC member-gathered data and other recent studies and presentations on the quality of Bakken crude oil.

Table 2: Bakken Quality Comparison, NDPC to AFPM and PHMSA

NDPC Rail Avg (1) AFPM Report PHMSA Report (5) Not Reported API Gravity 41.7 42 12.3 Vapor Pressure (psi) 11.5 7.83 (2) 87.0 IBP (°F) 100.3 69.6 (3) 4.65 (6) Light Ends (C2-C4s) (Liq. Vol. 4.95 3.5-11.9 (4)  Source – North Dakota Petroleum Council, 2014. Comments:

(1) Rail chosen because AFPM samples from Bakken at point of delivery, Rail data from (2) AFPM reported RVP, NDPC reported VPCR (D6377) at 37.8°C. AFPM also 4 reported (3) 87.3 Median, Multiple tests in AFPM data, some of which can report lower than (4) AFPM report, three respondents average 3.5%, fourth had 12 samples, range 5.9- (5) PHMSA data from Table E, data ranging from 3/17 to 5/2, to maximize overlap with (6) PHMSA does not report isobutane, and C2-C4 results do not appear to include isobutane. By comparison, NDPC C2-C4 without isobutane was 4.37  Source – North Dakota Petroleum Council, 2014.

3 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 While the test results from PHMSA’s report agreed closely with the NDPC results, the North Dakota Petroleum Council report claims that PHMSA did make some assertions in their Executive Summary which do not appear to be supported by their study or the above NDPC findings.

These parameter test results (above) prompted the NDPC to conclude that the Bakken formation oil meets the common definition or classification requirements of “Light Sweet Crude” (lower in sulfur) oil. Flammability and other hazard characteristics dictating what type of rail car should be used to ship Bakken crude in the past allowed most samples to be sent on any tank car. However, NDPC now recommends that all Bakken crude be shipped as a “Packing Group I” fuel, using DOT-111 rail tanker cars or better. Packing Group I is the designation given to products posing the highest degree of danger presented by hazardous materials, as is defined to represent “great danger.” Diluted Bitumen (Dilbit): The other product that the proposed pipeline would carry is diluted bitumen (dilbit) from Canadian tar sands. (See “Secondary Impacts” for an outline of the methods used to create bitumen.) Once the bitumen is separated from the matrix of clay, sand and other materials it is diluted with a very light, or low viscosity, hydrocarbon referred as diluent. The most common formulations of diluent include benzene or similar hydrocarbons. C - The EIS must include all direct, indirect and cumulative impacts of the two lines and the combustion of their products [or cargo - the oil]. R – The EIS will include these impacts, including impacts due to extraction of Alberta tar sands oil, global climate change, and risks of any efforts to ship oil of any type across Lake Superior. Consult – The Social Cost of Carbon “Researchers say the social cost of carbon will be 6 times the Obama administration's estimate”

The Social Cost of Carbon EPA and other federal agencies use the social cost of carbon (SCC) to estimate the climate benefits of regulatory rulemakings. The SCC is an estimate of the economic damages associated with a small increase in carbon dioxide (CO2) emissions, conventionally one metric ton, in a given year. This dollar figure also represents the value of damages avoided for a small emission reduction (i.e. the benefit of a CO2 reduction). The SCC is meant to be a comprehensive estimate of climate change damages and includes, but is not limited to, changes in net agricultural productivity, human health, and property damages from increased flood risk. However, given current modeling and data limitations, it does not include all important damages. As noted by the IPCC Fourth Assessment Report, it is “very likely that [SCC] underestimates” the damages. The models used to develop SCC estimates, known as integrated assessment models, do not currently include all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature because of a lack of precise information on the nature of damages and because the science incorporated into these models naturally lags behind the most recent research. Nonetheless, the SCC is a useful measure to assess the benefits of CO2 reductions. The SCC estimates using the updated versions of the models are higher than those reported in the 2010 TSD. By way of comparison, the four 2020 SCC estimates reported in the 2010 TSD were $7, $26, $42 and $81 (in 2007 dollars per ton of CO2). The corresponding four updated SCC estimates for 2020 are $12, $43, $65, and $129 (in 2007 dollars per ton of CO2). In June, 2015, the Province of Alberta proposed greatly increasing its carbon tax, in part to help maintain the viability of its petroleum products on the world market should climate impacts become a stronger market factor. Whether this increase would result in a reduced rate of production of tar sands petroleum is unclear, but the consensus is that it would not have much impact at the proposed rate of $30 per ton of carbon (Hulac 2015). C - Delay consideration of these projects due to the possibility that MN PUC may reroute Sandpiper in MN so it bypasses Wisconsin. Line 3 is a NEW line, requiring a Presidential permit amendment.

4 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R – WDNR administrators are in contact with MDNR reviewers regarding a potential re-route. Meanwhile, the environmental analysis of the proposed project will proceed by first analyzing potential impacts that could exist regardless of the pipeline route. C - Getting pipeline permits takes too long. R - Reviewing the potential impacts of and permitting an energy project can be a very detailed process, depending upon the nature of the environmental resources that could be affected and the technical details of the project. WDNR is responsible for protecting environmental values to the full extent required by state law, which requires and adequate review. WNDR staff cannot conduct an adequate review of a pipeline permit application until an application for a project is complete. Especially in more complex projects through areas of the most valuable natural resources, sufficient information for making determinations may be lacking with the initial application, and gathering the necessary data can take additional time. WDNR staff work within a permit process that prescribes time limits for completion of a variety of tasks. The average length of time for issuing a permit for a pipeline project is under 6 months from the time an application is deemed complete. At times the technical complexity of a project or the richness or vulnerability of natural resources that could be negatively impacted by a pipeline project can require an extended environmental review, which can take additional months. The general public, including people who have statewide policy or economic questions, in addition to people living along the proposed route or near pump stations, pose concerns and questions that require time to research. Meeting the public right to full information by fulfilling the role of an EIS as a disclosure document is an important function of WDNR permit reviews.. If there ever were a time when a critical pipeline was delayed due to permitting requirements and reviews, the flexibility of the American communications and transportation systems would enable people to use ride sharing, public transit, bicycling and renewable fuels to conserve energy and live within the fossil fuel supply that would be available through existing sources. C - Be sure to allow Native Americans to testify regarding this project. R – Due in part to their Ceded Territory treaty rights, WDNR has a staff person assigned as a tribal liaison to keep Wisconsin’s tribal governments apprised of projects such as this, and to solicit their input periodically. In addition, an EIS draft and hearing notice will be provided to individual tribal governments within the area, as well as to GLICWC, which functions as an umbrella environmental management agency for 11 Ojibwe/Chippewa tribes. C - Hold an EIS hearing in Madison in addition to one in the Lake Superior basin. R – WDNR will hold a hearing on this EIS project in Madison, as well as in Superior, and may consider a central Wisconsin hearing location as well if support for one develops. Purpose and Need C- The need for this project has not been established. Can conservation, better fuel economy and other measures negate the supposed need for the increased pipeline capacity? [referring to Line 61 also?] R – The applicant has provided its corporate purpose for the proposed project. While it is frustrating to many concerned citizens, neither the Legislative nor the Executive branches of the state or federal governments have chosen to develop a cohesive, broad-spectrum national or state energy policy. Therefore, there exists no government-sanctioned energy plan to use as a context in which to evaluate this pipeline proposal. These projects are not necessarily related to state or U.S. energy use, with at least some of the oil envisioned to be transported through the pipelines intended for export as gasoline of other refined petroleum products. Further, it is clear that both the Canadian government (in the case of tar sands crude oil), and the varied large and small energy corporations that have rights to the Bakken Formation crude oil, are lobbying extensively for permission to ship their crude oil to other nations. Shipment/export of crude oil originating in the United States to other countries is currently prohibited, but export of refined petroleum products is allowed. Canadian-origin crude oil is also being exported from the United States via pipeline systems originating in Canada, resulting in Canadian producers receiving higher prices on the world market than they would recieve (Lewis 2015). Canadian companies have proposed various pipeline projects as a means of exporting more of their petroleum

5 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 via the United States Gulf Coast, as well as to Canadian and American East Coast ports (Trichur 2015) and to the Canadian Pacific Coast in British Columbia. Further, forecasts in early 2015 foresee the potential for oil prices to rise by 2040 from the current $45/barrel to around $250/barrel, and for natural gas prices to more than double over the same period, from the current average of $3.73/million Btu to around $8/MMBtu. This assumes that the planned increases in exporting refined petroleum products will occur (Mandel 2015). This scenario is not accompanied by any analysis of what the potential impacts would be regarding drawing down US domestic fossil fuel supplies to sell to foreign markets. Another condition related to need is whether the existing pipeline system from the Superior storage facilities is adequate to transport the additional volumes of crude oil that would arrive in Superior due to the proposed project, to refineries to the east and south of Wisconsin. Is current pipeline capacity from Superior adequate to transport crude oil south and east to refineries, or will capacity of existing pipelines to the east and south need to undergo a capacity expansion or a new pipeline be necessary? – Isn’t that the purpose of the Line 61 project capacity increase, to accommodate the increased flow from a new Line 3? There is also speculation that this pipeline will also be used to transport tar sands crude, especially in the event that the proposed Keystone XL pipeline is not approved for construction at the federal level. Keystone is proposed expressly to move tar sands crude but would also be routed to enable conveyance of Bakken oil from North Dakota and Montana. Tar sands crude shares the sulfur-laden, heavy crude characteristics of much of the oil that the U.S. has been importing and processing at specially modified refineries along the U.S. Gulf Coast. The Keystone XL pipeline is proposed as a means to transport Canadian tar sands crude to those coastal refineries that are primarily in Texas and Louisiana. Some of that tar sands crude may be refined and used in the United States, and the remaining tar sands crude may be refined for export outside the U.S. or exported as crude oil to other markets The potential exists that in the event the U.S. prohibition against exporting crude oil is lifted, Canadian tar sands oil may be exported in much larger volumes without being refined in the U.S. Bakken oil production is currently (Dec 2014) at about 1 million barrels per day, comprising 25% of total US production. About 65% of that production volume is shipped to refineries by rail to destinations that range from the West Coast, to the Gulf Coast, to the Atlantic Coast. C - It is not at all clear what the need is for this oil in the U.S. (see Energy Security issues). Driving in the U.S. has decreased since 2006. Refinery capacity has increased in about the same time. A record amount of gasoline was exported from the U.S. in 2012 to South America. R – Numerous views exist regarding petroleum energy policy, market forces, conservation, energy independence, technological limits and other factors that impact the fossil energy industry. These are not regulated by the DNR but are important considerations for decision-makers. Here are some factors relevant as of 2014 (keeping in mind that the energy industry can be very volatile as is apparent with the late-2014 energy supply glut and price drop, meaning these factors are subject to rapid change):  In the United States, businesses and individuals use (add current petroleum use figures (2014)  One barrel of oil contains 42 U.S. gallons and this oil is refined to produce a number of products. According to the US, Energy information Administration (EIA), refiners convert those 42 gallons of oil, on average, into 19 gallons of gasoline, and a host of other products. Those other refined products include distillate and residual fuel oils, jet fuel, and petroleum coke. The proportion of these individual products often varies among refineries and from month to month because refiners adjust their output to meet fluctuating demand for various products as a means to maximize refinery profits (see http://www.eia.gov/tools/faqs/faq.cfm?id=24&t=10).  A significant amount of refined petroleum products, crude oil, and liquid natural gas (LNG) have for a long time been exported from the U.S. to other nations, weakening the claim that expanded transport of oil is needed across the U.S. for U.S. energy independence.  The US currently (November 2014) produces a total of about 9 million barrels of oil per day (EIA 2014n) (http://www.eia.gov/forecasts/steo/). Total crude oil production is projected to average 9.3 million bbl/d in 2015 (US EIA 2014 - http://www.eia.gov/forecasts/steo/pdf/steo_full.pdf)

6 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015  The US currently (2013) imports 7.6 million bbl/day of oil. This comprises about 40% of total US oil product use. This import volume is about 10% less oil than the nation imported in 2012, but still equals the amount imported in 1996 (US EIA April 2014). The largest volume of imported oil comes from Canada, followed by Mexico, and then Saudi Arabia. (?)  The US currently exports an average of more than 4.2 million barrels per day of refined petroleum products and crude oil (EIA 2014). These products include low sulfur diesel to Europe and refined gasoline to South American nations (Landers 2012).  Compared to 2013 levels, US exports of crude oil have more than doubled from January through September, 2014, to over 314,000 barrels per day.  Increased production of oil in the Bakken (centered in North Dakota), the Marcellus (Pennsylvania and surrounding states), Eagle Ford and Barnett (both in Texas) shale formations has created lower oil prices (as of December 2014), making the more expensive extraction of tar sands petroleum less competitive or at least less profitable. It has also caused the cancellation or postponement of a proposed oil pipeline that would carry oil from the congested transportation hub of Cushing, OK, to 8 refineries on the Texas [and Louisiana?] Gulf Coast, which constitute the largest center of oil refining capacity in the world.  Due in part to falling U.S. domestic prices (as of late 2014), oil and gas producers are steadfastly lobbying Congress for permission to export crude petroleum for the first time since the 1973 Oil Embargo, to seek higher prices available in Asia and South America. They are also lobbying for faster approval of facilities for exporting LNG produced in the U.S. (Snyder and Wingfield 2014; Philips 2012).  Energy and pipeline companies in Canada are seeking routes across Canada to bring tar sands crude to the Canadian coasts for export to nations other than the U.S., again weakening claims that pipelines are essential for U.S. energy security.  Production in the Gulf of Mexico from shallow and deep wells is expected to hit a new high in 2016, then plateau for about 5 years, then decline beginning around 2021 (Davis 2104 - http://www.naturalgasintel.com/articles/100406-marked-production-growth-ahead-for-deepwater-gom- says-wood-mackenzie). Also http://www.reuters.com/article/2014/10/31/us-usa-crude-exports-kemp- idUSKBN0IK20L20141031.  Refinery capacity increases over the past couple decades have reportedly been for refining high-sulfur crude oil imported from South American (e.g. Venezuela) and Middle East (e.g. Saudi Arabia) C - Can’t additional energy conservation measures make this pipeline expansion unnecessary? Carbon fuels should be rationed in North America, to render this expansion unnecessary. R – The Alberta Clipper pipeline expansion would allow pumping of 120,000 more barrels per day of crude oil. This represents significant additional risks that must be examined. The current permit does not stipulate that the company is allowed to expand the project, C - Line 61 currently carries about 400,000 bpd of tar sands oil and is proposed have its capacity expanded to about 1.2 million bpd (for Bakken, also, or all tar sands?). If there was an irrefutable need for this expanded amount of oil, it is interesting to see if that amount could be replaced by conservation and/or renewable fuel production. R –

Figure 1 - Comparison of Pipeline Capacities

Development of Energy East, a Canadian pipeline to pipe tar sands oil from Alberta to eastern Canada, has been suspended as of late 2014, in order to better study its potential impact on beluga whales, which were declared endangered in 2014. Energy East would be North America’s largest oil pipeline (unless the Line 61 expansion is completed as planned), carrying as much as 1.1 million barrels a day and stretching 4,600 kilometers (2,859 miles) from Alberta to New Brunswick. Penty 2014. 7 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 C - For vehicle fuels – name the destination of each line, describe where the crude oil is to be refined, and list the end sites and uses of the refined products [for domestic use? – If so for what region(s), or for export, and if so, to what countries?]. R – Information essential to tracing the refining of crude oil and destination of refined vehicle fuels may be difficult to obtain and time-consuming to interpret. What is known is that about 70% of crude oil extracted from the Bakken Formation in North Dakota is shipped out of North Dakota by rail, to oil hubs like Cushing, OK, and to refineries along the U.S. Gulf Coast. Also, while export of US crude oil is currently prohibited, exporting refined petroleum fuels and other products is not prohibited under federal law. Refined products have been exported from the US annually the nations of (add country names from list elsewhere). Because tar sands oil is more costly to extract and process than conventional crude oil and frack-extracted oil, the profit margin (as of late 2014 and early 2015) is comparatively small. This makes exporting refined tar sands products to countries willing to pay higher prices an especially attractive option for Canadian producers and American shippers. There is also a concerted effort to remove the prohibition on export of US crude oil. This is due in large part to the fact that US oil producers are extracting more oil from US domestic wells than they have markets for. This has caused prices for crude oil to decline, which in turn makes producing oil from tight shale formations (as well as from Canadian tar sands) less cost competitive. Lifting the export ban would allow US energy companies to sell US crude oil on the international market, and to receive the higher price available on the international market without having to refine the oil at the higher US cost. It is also true that oil from various sources can be combined in the process of being shipped to and processed by Midwest and Gulf Coast refineries. These fluctuating market factors make it extremely unlikely that the oil shipped through the proposed Sandpiper pipeline could be traced meaningfully through the distribution chain to any specific importing nation or end use internationally or domestically. C - For all products carried in the pipeline, where is the product going once it reaches the Superior terminal, and by what mode(s) of transport? C - Tar sands oil to be shipped on this line is costly to produce, so it needs to be sold in foreign markets like China, which pay more and offset the higher production costs. Much, most or all of this tar sands oil will not benefit Wisconsin or the U.S., but is destined for use in foreign markets. C - Don’t accept company line of “responding to market demand and customer need” because domestic demand is flat. The emphasis is on meeting the needs of oil refineries instead of on meeting the energy needs of the United States. http://www.eia.gov/dnav/pet/pet_move_exp_dc_nus-z00_mbblpd_m.htm R – It is true that much of the Bakken and Alberta tar sands oil that would be shipped through the proposed pipeline would be transported to refineries in the U.S. Gulf Coast. For decades until now, these refineries have been modified to process “light sweet crude” that has composed a large portion of U.S. oil imports. There is also a push to rescind the U.S. prohibition against exporting U.S. crude oil. India, China, Japan, and other Pacific nations are interested in importing U.S. crude oil due to their concerns over turmoil and uncertainty in the Mideast, which currently supplies much of their petroleum products (PTI 2014). [http://articles.economictimes.indiatimes.com/2014-10-28/news/55521560_1_oil-exports-oil-imports-oil- minister-dharmendra-pradhan] European nations may also be eager to welcome imports of U.S. crude, given concerns over the behavior of the Russian government and its annexation of parts of Ukraine. The US Energy Information Administration (EIA) updates its International Energy Outlook every year, with a more detailed analysis every two years. Their current (2014) forecast, which extends to the year 2040, estimates that US liquid petroleum fuels use will (summarize trend predicted in this report) C - Oil is running out, as seen by use of costly fracking and tar sands extraction methods. We are past Peak Oil and we should keep our remaining oil for more essential uses and use electric cars.

8 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R – The supply (or “reserves”) of oil on earth is indeed dropping daily through ever-growing use around the world. The concept of “Peak Oil” became prominent in the 1950s when a petroleum geologist predicted, based in known reserves and projections for demand at the time, predicted that the peak of US oil production would occur around 1970. However, according to the most recent study by the U.S. Energy Information Agency (EIA), the peak of world oil production has not yet occurred, as production continues to grow around the world (EIA 2004). Current forecasts based on recent supply and demand analyses, in concert with projected oil reserves and technological advances in oil extraction suggest that the peak of world of oil production will likely occur sometime around 2040, in less than a quarter century. Current (2015) US oil uses (or “demand”) are supplied from a variety of sources. For the second half of 2014, the United States imported approximately 40% of the oil it used (approximately 275 million barrels per day), from a wide variety of sources. Supplying countries include 11 OPEC nations within and apart from the Persian Gulf, and 64 other countries across South America, North America, Africa, Asia, and Europe (EIA 2015). See http://www.eia.gov/dnav/pet/pet_move_impcus_a2_nus_ep00_im0_mbbl_m.htm for the table “U.S. Imports by Country of Origin.”

Global oil demand is being supplied by a much wider range of sources, including (list significant sources) Iraqi oil was important to the U.S. economy [and Canadian crude is needed to make up for the loss of some of that since 2002?] (U.S. crude imports (1.5 billion barrels/year?) from Iraq were 4.5% of total US oil budget in 2001 and 1.7% (700 million barrels/year) in 2006.) Canada is the biggest exporter of oil to the U.S. Total U.S. imports from Canada equal 33% of all petroleum (total petroleum products) we use, and 50% of the crude oil that we refine. (June 2014 – Canada exports 3.2 million bbl oil/day to U.S. - http://www.eia.gov/petroleum/imports/companylevel/) (But how much of that stays in the U.S.?) The Bakken Formation itself is reported to hold about 200 billion barrels of “oil equivalent.” This oil formed during the late Devonian and Mississippian epochs, roughly 320 million to 360 million years ago. The oil is held within shale rock layers beneath portions of North Dakota, Montana, and Alberta. Of that, estimates of the amount of oil that can be extracted by existing technology (primarily hydraulic fracturing, or fracking”) range from 6 billion to 40 billion barrels. As of 2014, approximately 1 billion barrels of oil have already been extracted from this formation within a period of about 5 years (http://bakkenshale.com/). This translates to continued production from the Bakken field alone, at current (Nov. 2014) rates, for roughly another 25 to 195 years, assuming that well yields would remain comparable to what they were in 2014. In the Gulf of Mexico, (as of late 2014) oil analysts expect the volume of oil extracted from deepwater and shallower water oil wells to increase through 2016, then level out or “plateau” for the next several years, at current rates of pumping. The rate of oil extraction from this major oil producing area is then expected to begin decreasing, beginning around 2021. World-wide, conventional oil production (that oil produced from traditional wells producing lighter crude oil, which does not include oil produced from water-dependent and chemical-intensive hydraulic fracturing or energy-intensive tar sands processing), is expected to last approximately another 50 years. The U.S. imported about 9 million bpd of crude oil and oil products during the period 10/10/14 – 11/14/14. This includes about 7.3 million bpd of crude oil (largely “heavy” by reports) and 1.3 million bpd of refined petroleum products, including gasoline, fuel oil, jet fuel and propane.

At the same time, the U.S. continues (as of 2014) to export crude oil to Canada at an exponentially increasing rate. In 2009, U.S. energy companies exported 1.1 million barrels per month to Canada. By late 2014, U.S. exports of crude oil to Canada hit 11.7 million bp month. By federal law (since 1975) exports of crude oil to Canada are supposed to be used within Canada, but there may be no mechanism to track the fate of this U.S. oil. Meanwhile, oil companies are pressing heavily for repeal of the control on crude oil exports, so they can

9 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 maximize their profits by selling US-sourced crude at the highest prices available in the shortest time frame, irregardless of the future impact on US national security.

Regardless of what year the Peak Oil scenario occurs, many observers believe that history should dictate that the U.S. devise a cohesive, broad-spectrum plan for its energy future. As North American production declines, the U.S. will once again become more and more dependent on imports from various regions of the world. The greatest remaining world oil reserves and therefore the most likely future suppliers will be in Middle East nations. In light of the growing lack of social and political tolerance between and among the various nations and cultures in this region, it would be a wise choice for the US to embark upon a program that includes both oil conservation and the development of large scale production of alternative fuels. As history demonstrated during the 1973 “Arab Oil Embargo” against the US, relying heavily on this region for our energy security can have serious drawbacks. Expanding exports of North American crude oil only brings this time of potential dependency closer, and at a faster rate.

It should be an important consideration that regardless of the duration of availability in the world, Wisconsin has no fossil fuel reserves or production whatsoever. Every gallon of crude oil, refined gasoline, and other petroleum products spent in Wisconsin goes out of state.to enrich the economies of other states and nations. On the other hand, some of the dollars spent in Wisconsin on renewable bioenergy/transportations fuels, such as ethanol, stay in Wisconsin to enrich our economy, because Wisconsin does produce some ethanol that is mixed with gasoline and which could be used to power some transportation vehicles without the addition of gasoline.

C - Will or could these oil pipelines be used at some future time to export water from Lake Superior? R – Currently, DNR knows of no plans to convert any oil pipelines to carry water away from Lake Superior. However, during times of relatively high oil prices and low natural gas prices, some pipeline companies have proposed converting natural gas pipelines to transport oil instead. Any proposal to transport Great Lakes water via an existing oil pipeline (or a dedicated water pipeline) would require approval under the Great Lakes Compact. The Great Lakes Compact is a formal agreement among the Great Lake states. A parallel agreement includes the two Canadian provinces that border the Great Lakes and the St. Lawrence Seaway. In these agreements, the states and provinces agree to manage the water in the Great Lakes watershed collectively. The agreements also ban Great Lakes water from being "diverted," or piped out of the basin as of December 8, 2008, except under a few limited and strictly regulated exceptions. The Great Lakes Compact became effective on December 8, 2008 after final consent from the U.S. Congress [PDF]. Beginning on this date diversions of water out of the basin were banned. Also beginning on that date, each of the Great Lakes states were given five years to develop a water management program with the elements required by the compact. Wisconsin passed implementing legislation (see http://docs.legis.wisconsin.gov/document/statutes/281.343) for the compact in 2008 and had its required management program fully in place by the end of 2011 (WDNR 2015). (WDNR 2015 – Jan 28) http://dnr.wi.gov/topic/greatlakes/compact.html Affected Environment C - Include within the affected environment all of Lake Superior, not just the streams that the pipeline crosses. R – (Include sections from Ecological Landscapes – Superior Coastal Plain EL and Hydrology) Lake Superior offers a wealth of ecological and socio-economic resources. The Wisconsin segment of the proposed pipeline would lie entirely within the Lake Superior basin. Any negative impact to the streams tributary to Lake Superior that the proposed project would cross can be conveyed quickly and directly to the lake itself. The human population of the Lake Superior basin is approximately 607,000, with more than 425,000, or 70% of those residing in the United States. Many of the residents of the Lake Superior watershed rely on the lake for their personal, economic and social well-being. Lake Superior holds 10 percent of all the fresh water on Earth, and it is regarded as clearly the least degraded of all the largest freshwater bodies not only in the Great Lakes region, but on all of our Earth. 10 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 People living in the Lake Superior basin rely heavily on the lake for healthful drinking water and for clean water for industrial processes. As of 2012 municipal wells in the US and Canada pump an average of 98 million cubic meters per year for drinking water and other purposes. Industries make use of another 1.13 billion cubic feet per year (USEPA 2012) of water from Lake Superior. C - Include within the affected environment all of the 1837, 1842 and 1854 Ceded Territory. [1836 is entirely in current State of Michigan.]

Figure 2 - Ceded Territory of the Upper Great Lakes. Source: GLIFWC R – The area potentially affected by the proposed Sandpiper pipeline is only within the Ceded Territory of 1842. (Include sections from Ecological Landscapes – Superior Coastal Plain EL and Hydrology and outline that area which is part of the applicable “Ceded Territory of 1842). Much of the Ceded Territory is outside of the Lake Superior Basin. Compile an inventory of fish and wildlife resources along the proposed corridor and in all downstream areas that could be affected by construction and operation of the line, in order to be able to assess impacts against baseline conditions. Highlight those species and communities that are most vulnerable to construction and spill impacts. Compile an inventory of ecologically sensitive areas along the proposed corridor and in all downstream areas that could be affected by construction and operation of the line, in order to be able to assess impacts against baseline conditions. Alternatives Acknowledge that the scale of this project is large, affecting far more than the 14 mile corridor in Wisconsin. Review a correspondingly broad scope of alternatives in the EIS. Include an alternative to pipe this oil straight down to refineries in Oklahoma, Texas, and/or Louisiana? Provide a continental scale alternative showing the most efficient way to meet U.S. energy needs. C - Alternatives – include shipping – spill hazard compounded by inability to clean heavy oil from deep cold water of Lake Superior. Shipping on Great Lakes is also a risky alternative. Detail and analyze those risks, which are part of the secondary and cumulative impacts of the proposed project. 11 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R – A number of states, including Wisconsin, use oil shipped by barge or serve as loading areas for oil barges. In California, more oil enters the state’s refineries by barge as of 2014, than enters by rail. These barges carry about 50,000 gallons each, whereas most of California’s oil use is supplied from Alaska via tanker ships that carry around 500,000 barrels. Shipping oil by barge or tanker carries risks like all other oil transportation methods. Numerous collisions and other incidents have occurred in US waters and all around the world that have resulted in oil spills. On January 2, 2015 a Libyan registered oil tanker collided with another ship off Singapore and spilled 4,500 tons (about 42,000 barrels) of crude oil into the South China Sea. In February 2014, a 65-mile stretch of the Mississippi River, including the Port of New Orleans, was closed to all water traffic as crews cleaned up oil that spilled from a barge after it ran into a towboat between Baton Rouge and New Orleans (AOL 2014). http://www.aol.com/article/2014/02/23/oil-leak-closes-65-mile-strech-of-the-mississippi-river/20836324/ In March, 2013, a barge carrying 80,000 gallons of light crude collide with a railroad bridge near Vicksburg, MS, spilling oil into the river and necessitating closure to navigation to clean up the spill. http://www.huffingtonpost.com/2013/01/27/mississippi-river-barge-crash_n_2564418.html A month previous to that, an oil spill closed a portion of the lower Mississippi River for less than a day last after an oil barge and a construction barge collided, spilling less than 10,000 gallons of oil. In 2008, a fuel barge collided with a tanker and broke in half, dumping 283,000 gallons of heavy crude into the lower Mississippi, and closing the river for six days. http://www.huffingtonpost.com/2013/01/27/mississippi-river-barge- crash_n_2564418.html C - Alternatives – include rail – spill and explosion hazards from rail cars of substandard strength; also contribution to rail traffic delays for agricultural and other commodities and passenger rail service. Trains carry crude oil to Minneapolis refineries now. A rail benzene spill in the Nemadji River at Superior in 1992 shut down service for a time. R – (Pare these and any more recent incidents down to relevant summary information) See also rail impacts summary from product characterization, above.) As of 2014, approximately 70% of all Bakken crude oil extracted is shipped out of North Dakota by rail. This has created a number of substantial impacts and has resulted in rail shipment catastrophes in North Dakota, Alabama, and Quebec (Lac-Mégantic). Around the country, railcars move about 800,000 barrels of oil per day, or 10% of total U.S. crude oil shipments. Shipping crude oil by rail continues to grow in the face of delays in approving and constructing proposed pipelines. In the United States in 2009 there were 10,888 carloads of oil shipped by rail. By 2013 there were 400,000 carloads shipped by rail. (http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/?vgn http://www.canadianmanufacturing.com/environment-and-safety/lac-megantic-cn-cp-plan-replace-fix-dot-111- tank-cars-135975/ extoid=c6efec1c60f23410VgnVCM100000d2c97898RCRD&vgnextchannel=d248724dd7d6c010VgnVCM100 00080e8a8c0RCRD&vgnextfmt=print). In Wisconsin, on average 34 oil trains per day pass along the Mississippi River from Minnesota and into Illinois. Another four oil trains per on average pass through south central Wisconsin. The freight rail companies transporting oil alert state emergency management staff to plans to route oil train shipments through the state, within a window of time. As the routing date approaches, rail shippers provide more details on route and schedule and state emergency managers alert emergency response staff in each county through which the shipments are scheduled to pass (Woodbury 2014). Many of these trains converge in Chicago, which sees on average 199 oil trains per day (WSJ 2014). While oil spills from rail shipments are not common, numerous oil spills, fires, and at least one disastrous explosion have demonstrated the risks associated with transporting oil by train. Some of the more recent among these occurred in Quebec, North Dakota, and Alabama in 2013, and Ontario and West Virginia in 2015. Lac-Mégantic , Quebec: On July 5 and 6, 2013, in Lac-Mégantic, Que., fire, derailment and explosions devastated the town and killed 47 people in one of Canada's worst rail disasters. Many of those killed were 12 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 patrons in a popular café near the railroad tracks. Approximately 100,000 liters (about 26,000 gallons) of oil spilled from several tank cars into the Chaudière River. About 1,460,000 gallons burned in a disastrous fire (http://www.cbc.ca/montreal/features/lac-megantic-oil-amount-graphic/). As of May, 2014, despite efforts to clean the riverbanks and sediment, a 30-kilometre stretch of the river still had considerable levels of oil along its bed. http://www.cbc.ca/news/canada/montreal/lac-m%C3%A9gantic-rail-disaster-oil-remains-in-chaudi %C3%A8re-river-1.2639732 So far (May, 2014), the province has spent $16 million to clean up the river and much work remains to return the river to its original state. On January 10, 2015, the parties involved announced an agreement that the railroad would pay $200,000,000 in compensation to surviving victims and the families of the deceased.

Aliceville, Alabama: On Friday, November 8, 2013, a train near Aliceville, in Pickens County, Alabama was travelling on relatively flat terrain at below the 40 miles per hour limit. An industry-standard two engineers were driving it, not one as in Canada. The accident happened in a wetlands area that eventually feeds into the Tombigbee River, according to the Alabama Department of Environmental Management. Booms were placed in the wetlands to contain the spilled oil.

Don Hartley, regional coordinator for the Alabama Emergency Management Agency, said the tank cars originated in North Dakota and were carrying the more volatile and explosive Bakken crude oil. Three cars had a "'bleve' - where pressure builds up and blows a hole. "That started the fire,” he said. However, it was not known why the train derailed.

With no apparent extenuating circumstances, experts said investigators would likely be looking hard at the condition of the tracks themselves, noting that short-line railroads like the one in Alabama have become critical final links in the thriving oil-by-rail trade - but can suffer from neglect.

Just days before the accident, in fact, Genesee executives had talked to analysts about the challenges of upgrading the assets they inherited a year ago after buying RailAmerica, becoming the country's largest short- line railroad operator.

In Friday's incident, Genesee said the train was hauling 90 T108 tank cars. A Department of Transportation spokesman later said that the T108 designation is an equipment code used by the industry, and that the cars involved were all DOT-111s -- the formal specification for the most popular type of tank car. A local official said the crude oil had originated in North Dakota, home of the booming Bakken shale patch. If so, it may have been carrying the same type of light crude oil that was on a Canadian train that derailed in the Quebec town of Lac- Mégantic in the summer of 2013. Casselton, North Dakota: On December 23, 2013, a train carrying tankers of Bakken crude derailed and several cars burst into flame approximately one mile outside Casselton, ND. No one suffered any acute injuries from the derailment of this one mile-long train, but the crash sent a great fireball and plumes of black smoke skyward. The fire was so intense as darkness fell that investigators couldn't get close enough to count the number of burning cars. Most residents heeded a recommendation to evacuate their homes as strong winds blew potentially hazardous, acrid smoke toward the town overnight, Mayor Ed McConnell said early Tuesday. The North Dakota Department of Health warned that exposure to burning crude could cause shortness of breath, coughing and itching and watery eyes. It had said those in the vicinity with respiratory conditions such as asthma, bronchitis or emphysema should minimize outdoor activity. Plaster Rock, New Brunswick: On January 7, 2014, a 122-car CN train whose cargo included butane gas and crude oil derailed three miles from Plaster Rock, New Brunswick and burned for four days. A total of 19 cars, including several containing crude oil, and one locomotive on the four-locomotive train went off the rails, igniting the fire. None of the cars bearing butane left the tracks or were affected by the burning oil. The 13 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 derailment and subsequent fire prompted the provincial Health Department to issue an air quality alert for the Plaster Rock area and an advisory about water use. The regional medical officer of health for the area said residents should take precautions when heavy smoke affects air quality. "Infants, children, pregnant women, older adults, smokers and people with chronic heart or lung diseases should stay indoors to reduce their exposure to the outdoor air," said Dr. Yves Léger. Those who live in the evacuation zone were advised not to consume water until quality is assured. Anyone experiencing difficulty breathing or chest discomfort is advised to contact a physician (CNC News 2014). Lynchburg, Virginia: On April 30, 2014 a 105-car CSX oil train derailed in downtown Lynchburg, Virginia. At least three rail cars fell into the James River, resulting in crude oil leaking out of punctured tank cars, and setting the James River on fire. The wreck spilled at least 50,000 gallons of crude oil. An unknown amount of the spilled oil was burned on the surface of the river after it ignited, while the remainder was carried downstream on the current. Several of the 17 tank cars that went off the track and fell into the James River were newer DOT 1232s, including one that ruptured and spilled about 30,000 gallons of Bakken crude, causing a massive fire (WDBJ7 2015, ENS 2015). Timmins, Ontario: On February 14, 2015, a Canadian National (CN) freight train hauling 100 tank cars of crude oil derailed in a remote wooded area of northern Ontario, about 48 miles south of Timmins. Several cars caught fire. Twenty nine rail cars in the 100-car train derailed, and seven caught fire. No one was injured as a result of the incident. At last report, frozen soil and the distance to the nearest streams may have prevented widespread water resource contamination (ENS 2015, ).

Mount Carbon, West Virginia: On February 16, 2015, a CSX train hauling at least 100 tanker cars carrying three million gallons of Bakken crude oil derailed during a snowfall in early afternoon along a flat stretch of rail line near Mount Carbon, West Virginia. At least one oil car fell into the Kanawha River and at least 14 others burst into flame, pushing searing fireballs more than 300 feet into the sky. One home burned and at least 200 nearby families had to evacuate the area, but no injuries to people were reported. The towns of Mount Carbon and Cedar Grove had to close their drinking water intakes in the Kanawha in order to avoid contamination of already-treated drinking water. CSX said all of the tank cars were CPC 1232 models, which feature safety upgrades voluntarily adopted by the industry four years ago, the Federal Railroad Administration confirmed Tuesday. The 1232s are supposed to be safer than the older DOT-111 tankers, which the federal government is seeking to phase out because they have been found to be vulnerable to ripping open in an accident or derailment, resulting in fires and explosions. Gordon Wren Jr., Rockland, West Virginia's Fire and Emergency Service director, said it was "worrisome" that the purportedly tougher tank cars failed. "Even with the better tank cars, accidents will still happen and they can still fail. You're talking about tremendous weight and energy," Wren said. He added the opinion that oil companies “should pay for the best available technology to minimize risks to local communities.” Galena, Illinois: On March 5, 2015, a 103-car Burlington Northern train with 100 oil tank cars had 21 cars derail, with five catching fire and burning for days, in a wooded rural area near the confluence of the Galena and Mississippi rivers. The fire suppression and spill containment response included a team from Grant County, Wisconsin. This train was also reported to be hauling oil in newer, upgraded CPC-1232 tanker cars (AP 2015). Heimdal, North Dakota: On May 6, 2015, the town of Heimdal, N.D., was evacuated after an oil train derailed and caught fire. Ten cars of the Burlington Northern-Santa Fe Railway train went off the tracks in a rural area about 2 miles from Heimdal. No injuries had been reported, but 35 people have left Heimdal as a precaution, said Wells County Emergency manager Tammy Roehrich. The Federal Railroad Administration has sent a team to investigate the cause of the derailment. Other Rail Safety Concerns On Canadian National track alone, an average of more than 20 crashes and spills occur each year, including at least 5 reported in Wisconsin from 1994 – 2014. The cargo spilled into lakes, streams, wetlands, forests, farmlands and urban areas includes not only petroleum products, but also ethanol, toxic industrial chemicals, grain and coal (see examples at: https://railroaded.files.wordpress.com/2014/05/cn-railway-derailments-other- 14 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 accidents-and-incidents1.pdf). Further, CN is believed to have failed to report hundreds of smaller derailments and other incidents of rail safety failure. Rail car safety improvement The Lac-Mégantic, Quebec, Aliceville, AL, and other accidents noted above, as well as other spills and crashes involved DOT-111 rail tanker cars, which have been faulted by regulators as being prone to puncture. The rail industry voluntarily adopted new standards for the 111s from October 2011, but has resisted efforts to revamp previous versions because they say it would cost $1 billion. DOT-111 railcars ordered after October 2011 have been manufactured to the new code, but the industry has resisted spending an estimated $1 billion to retrofit nearly 300,000 existing tank cars. http://www.huffingtonpost.com/2013/11/11/alabama-oil-train-derailment_n_4252887.html In summer, 2013, a Canadian train carrying Bakken light crude oil rolled down an incline as a result of the engineer’s failure to set the brakes and derailed in the Quebec town of Lac- Mégantic in the summer of 2013, killing 47 people. In Canada, the number of freight rail crashes is declining but the nature of cargoes, including the Bakken crude hauled by trains, seems to the Canadian Transportation Safety Board to be more hazardous (McDiarmid 2014). In California, four US representatives acting on behalf of concerned citizens are proposing that the US DOT make a number of improvements to rail safety regulations (Cooper 2014). In a letter dated July 1, 2014, they urge the US DOT to: • Provide a report on the level of compliance by the railroad and petroleum industry to the May 7 Emergency Order. • Issue rulemaking that requires stripping out the most volatile elements from Bakken crude before it is loaded onto rail cars. • Expedite the issuance of a final rulemaking to require the full implementation of the Positive Train Control (PTC) technology for all railroads transporting lighter crude, and provide a status report on the progress of PTC implementation to date. • Expedite the issuance of rulemaking that requires phasing out old rail cars for newer, retrofitted cars. In addition, US DOT is proposing a requirement that rail tank cars carrying oil meet or exceed a standard referred to as CPC-1232, for safety and spill resistance Estimates are that this safety upgrade would add 1.5 cents to 5 cents to the cost of a gallon of gasoline. https://rbnenergy.com/the-trains-they-are-a-changin-will- new-tank-car-standards-stifle-crude-by-rail-part-2. This railcar upgrade may still not be adequate to reduce the destructive impacts of rail car crashes and spills. Several such incidents have occurred involving the new CPC-1232 rail tankers, including the derailment and fire at Mount Carbon, West Virginia, noted above. World Natural Gas Reserves (Should be placed in Alternatives section) Natural gas is seen by some technologists and energy planners as a viable substitute for gasoline as a transportation fuel, in many applications. Current estimates of world unconventional natural gas reserves put the figure at approximately 308 trillion cubic meters (McGlade and Ekins 2015). http://www.nature.com/articles/nature14016.epdf? referrer_access_token=kokNMiigcMeMQHbbUXdyXdRgN0jAjWel9jnR3ZoTv0MEzzy4wDRQte5fViQxiPJjJI fgcjxiQpfQtqwAkMQY0N2caIEAG8DwqbHseLJCi6DfAOL44N-nwXOZqEUrnvrq Meanwhile, use of natural gas around the world (primarily for heating and industrial purposes) increased from 53 trillion cubic feet (or about 1.5 trillion cubic meters) in 1980 to 113 trillion cubic feet (or about 3.2 trillion cubic meters) in 2010 (US EIA 2012). The rate of use of natural gas continues to increase every year due to industrial expansion and the replacement of coal-fired electrical generation plants and other factors. This means that at the 2010 use rate and estimate of gas reserves there would be enough natural gas remaining to be tapped to supply world-wide use for less than ____ years. http://www.eia.gov/todayinenergy/detail.cfm?id=5810

15 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Jobs comparison, rail versus pipeline

Alternative – trucking oil can slow up food delivery [? - this is not really done over any great distance, is it?]. C - Why is there no proposal to route Canadian tar sands crude via a port in Canada, namely Thunder Bay for east-bound crude oil? Include that as an alternative. C - The need for this project has not been established. Can conservation, better fuel economy and other measures negate the supposed need for the increased pipeline capacity? Discussed in large part earlier C - Jobs can be created with safer energy sources and transportation fuels and modes. Stronger pipeline materials and additional safety valves Improvements in the strength of materials and in the ability to detect and minimize leakage from a pipeline can be installed, especially in the vicinity of lakes, stream crossings and wetlands. In an order approving a certificate of need for the Minnesota potion of this pipeline, the Minnesota Public Utilities Commission “encouraged” state officials who will oversee an in-depth environmental study of possible routes to consider additional protections for waterways, such as thicker pipes and additional shut-off valves in critical areas (Shaffer 2015). By all reports, however, these measures would have to be taken voluntarily unless federal law is changed, because federal authority currently preempts state regulatory powers. Construction Impacts Evaluate the potential for introduction and spread of invasive species along the construction corridor and into and along streams crossed by the pipeline. Document the measures to be implemented to avoid or control the introduction and spread of invasive species, and assess their effectiveness based on past results. Climate Change Impacts Include the relationship of an added increment of global CO2 increase from extracting and processing tar sands crude. C – Document that tar sands oil, due to the nature of its extraction process, is about 17% more carbon intensive than conventional petroleum. (AshBayCos LOWV). R - C - Include the relationship of an added increment of global CO2increase and related climate change from shipping, refining and burning tar sands crude. A pair of researchers released an estimate relating use of all fossil fuels globally to limiting climate change to 2oC. This study, summarized in 2015, looked at how much of the earth’s known fossil fuel reserves need to left in the ground through the year 2050. They concluded that, through 2050, all nations together need to leave unburned 33% of the world’s natural gas, 50% of the world’s oil and 80% of the world’s coal (McGlade and Elkins, 2015). This study further recommended that Canadian bitumen deposits remain comparatively undeveloped through 2050 (though producing 7.5 billion barrels from 2010 – 2050) due to the higher production costs involved and carbon dioxide emissions for extracting this energy, as compared to conventional oil. Canada reneges on emissions targets as tar sands production takes its toll - A new pledge to cut greenhouse gases by 30% from 2005 levels by 2030 is less ambitious than previous goal and lags far behind US and EU targets (Goldenberg 2015). C - Analyze the climate change-related carbon and other emissions output and climate change impacts on both local and regional scales. Incorporate the findings of the WICCI study and the Lake Superior Work Group. C - Document that climate science is demonstrating that our planet is in jeopardy from the impacts of our heavy reliance on carbon fuels – refer to the WICCI study. The buildup of fossil fuel combustion products threatens extreme weather, as noted in the IPCC report – “Hot and Hungry.” R - Many annual reports and cumulative reports have documented and continue to document the science and impacts of climate change. On September 3, 2014, the World Meteorological Organization (WMO) issued an interim report that “the year 2014 was on track to be one of the hottest, if not the hottest, on record, according to preliminary estimates. This is primarily due to record high sea surface temperatures around the world, which 16 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 will most likely stay above normal until the end of the year. High sea temperatures, together with other factors, contributed to exceptionally heavy rainfall and floods in many countries and extreme drought in others.” If December continues to follow the global pattern of above-average warmth, which would mean that 14 of the 15 warmest years on record would all be in the 20th Century. Average surface air temperatures over land from January through October 2014 were about 0.86°C above the 1961-1990 average, the fourth or fifth warmest for the same period on record. Global ambient air temperature increases Western North America, Europe, eastern Eurasia, much of Africa, large parts of South America and southern and western Australia were especially warm. As has been typical, some areas of the globe do not follow the trend of increased temperature, as demonstrated with cooler-than-average conditions for the year-to-date being recorded across large areas of the United States and Canada and parts of central Russia. In January, heat waves occurred in South Africa, Australia and Argentina in January. Australia experienced a second prolonged warm spell in May. Record heat affected northern Argentina, Paraguay, Bolivia and southern Brazil in October. Notable cold waves were reported in the U.S. during the winter, in Australia in August and in Russia in October. Global sea surface and subsurface temperature increases Global sea-surface temperatures were the highest on record, at about 0.45°C above the 1961-1990 average. Sea surface temperatures in the eastern tropical Pacific neared El Niño thresholds. Temperatures were also “unusually high in the western tropical Pacific Ocean, across the north and north-east Pacific as well as the polar and subtropical North Atlantic, southwest Pacific, parts of the South Atlantic and in much of the Indian Ocean.” Temperatures were also very high in the Northern Hemisphere from June to October, and the reasons for this are under scientific study. In the ocean at depths of both 700m and 2000m, heat content for January to June was estimated to be the highest ever recorded. When humans burn fossil fuels, the heat energy released is trapped by Earth’s atmosphere by greenhouse gases. An estimated 93% of this heat is taken up by the oceans. Therefore, the amount of heat in the oceans is critical to how our climate system operates and impacts us (West 2015). Rain event and drought frequency and intensity In 2014 through November there have been a number of instances of extreme rain events, severe flooding and prolonged drought across the planet. There have also been fewer Pacific cyclones than the average, though some were very intense. While it is not possible to know with certainty that any of these conditions are a result of ocean or global warming, meteorologists have predicted that climate change is likely to intensify many of these events (cite). Others studies show that climate change is likely to increase the frequency of intense winter storms, but will not necessarily increase the intensity of those storms (Nature 2015). The so-called “Snowmageddon” storm that brought Washington D.C. to a standstill in 2010, and the string of snowstorms that have set records for snowfall in the Boston area over the winter of 2014-15 appear to conform with this predicted consequence of a changing climate () While winter storms may increase in frequency only, a changing climate has been predicted to create more intense tropical storms due to the way they obtain energy from warmer water. http://www.nature.org/ourinitiatives/urgentissues/global-warming-climate-change/threats-impacts/stronger- storms.xml Flooding Scientists have found that flood events in the Midwest, including Wisconsin, have increased in number over the last 50 years. The researchers from the University of Iowa, funded by the National Science Foundation, studied 774 stream gauges across 14 U.S. states and found that rivers over much of the region have burst their banks more often, resulting in more flooding (Mallakpour and Villarini 2015). According to the study, 34 percent of these gauges showed an increase in flooding events from 1962 to 2011, while only 9 percent showed a decrease. “The thing that I was surprised about the most was that there was such a coherent change” across the whole region, said one of the study’s authors, Gabriele Villarini, a hydrologist 17 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 and engineer at the University of Iowa. Villarni described it as “a very homogeneous pattern.” That gave researchers confidence that the increase was the result of something more than simply localized weather or changes in specific watersheds, Villarini said. It was about bigger changes in the climate. There was “a nice, coherent pattern between rainfall and discharge” of rivers, he said. While the study does not attempt to pinpoint precisely how climate change might be directly responsible for these increased flooding events, the scientists say in the report that the changes “can be largely attributed” to changes in rainfall and temperature, with shifts in land surface temperatures “potentially amplifying this signal.” Annual average temperatures (red line) across the Midwest are rising .Annual average temperatures (red line) across the Midwest are rising (National Climate Assessment, 2014). That means the study’s findings are generally consistent with how climate scientists describe one of the major impacts of global warming: As the atmosphere warms, it can hold more moisture, resulting in more frequent episodes of intense precipitation, and therefore flooding. Last year’s National Climate Assessment reported that annual precipitation has increased over the past century, by up to 20 percent in some parts of the Midwest, in part “driven by intensification of the heaviest rainfalls.” That trend is likely to worsen. What is known is that the greenhouse gas content of Earth’s atmosphere continues to increase. The WMO report notes that “globally-averaged atmospheric levels of CO2 reached 396.0 parts per million (ppm), approximately 142% of the pre-industrial average. The increase from 2012 to 2013 was 2.9 ppm which is the largest year to year increase, with a number of stations in the Northern hemisphere recording levels above 400 ppm. The overall increase in atmospheric CO2 from 2003 to 2013 corresponds to around 45% of the CO2 emitted by human activities. The remaining 55% is absorbed by the oceans and the terrestrial biosphere.” Methane (CH4), a greenhouse gas more potent than CO2, hit a new high for atmospheric concentrations, at 1824 parts per billion (ppb) in 2013. This level is about 253% of the pre-industrial level. Atmospheric concentrations of N2O are now up to 121% of the pre-industrial level on a global level.” “NOAA’s Annual Greenhouse Gas Index shows that from 1990 to 2013, radiative forcing by long-lived greenhouse gases increased by 34%. CO2 alone accounted for 80% of the increase.” Flaring Impacts The oil that would be transported by the Sandpiper project would come not only from carbon-intensive tar sands oil production, but also from Bakken shale oil. Production of Bakken oil is accompanied by a vast volume of natural gas that is wasted via the process of flaring (as of early 2015). Flaring is essentially burning the natural gas (methane) that emerges from the oil wells, rather than capturing the gas for a productive use. A limited amount of flaring is deemed necessary in order to keep well pressures at safe levels, but the bulk of flaring is due to the absence of piping that could collect the methane for storage and eventual transportation to energy markets. The current estimate (2014) is that in North Dakota alone, one-third of total natural gas production (or approximately 400 million cubic feet of 1.3 billion cubic feet of natural gas produced daily) is burned into the atmosphere to no benefit of humankind or to any state or national economy. This in turn has produce 1.4 billion pounds (700,000 tons) CO2 from 2010 through 2014 from wells over the Bakken Formation in North Dakota. Industry analysts and representatives point out that while this is a wasteful practice in terms of energy and dollars, the release of carbon dioxide as a bi-product of flaring has less of a climate impact than would releasing (“venting”) unburned methane directly into the atmosphere (Kelly 2014). Flaring is an activity requiring a state air pollution permit, and the number of permit applications received by states, including those over the Bakken Formation, has increased steadily over the past ten years (see Table 1). Furthermore, the State of North Dakota has been routinely extending flaring permits, which were intended to expire after one year, despite rising complaints by landowners of increasing odors and health effects from exposure to poorly controlled air pollution emissions (Kelly2014). From space, the flames and lights from oil rigs flaring natural gas appear like a vast, medium density city large enough to support millions of people. (try Karin F, Dougal, Mike K re: formatting of title and generation of TOC)

18 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Table 1 Applications to Vent or Flare, by State - FY 2005 - FY 2014

201 State* 2005 2006 2007 2008 2009 2010 2011 2012 2013 4 Alaska 0 0 0 0 4 0 0 0 0 0 California 0 0 0 1 0 2 0 0 1 0 Colorado 4 7 9 1 46 46 80 72 23 30 Eastern States 0 0 2 0 0 0 2 0 0 4 Montana/Dakot as 2 3 6 15 24 40 82 138 163 492 New Mexico 15 26 39 27 37 40 73 154 499 558 Utah 1 0 4 18 18 55 36 15 35 25 Wyoming 28 17 34 77 136 226 349 68 52 139 1,2 Total 50 53 94 139 265 409 622 447 773 48 http://www.theecologist.org/News/news_analysis/2562341/us_shale_oil_drillers_flaring_and_venting_billions_ of_dollars_in_natural_gas.html A new report from Earthworks finds that drillers in North Dakota alone have burned off over $854 million worth of gas at shale oil wells since 2010, generating 1.4 billion pounds of CO2 in 2013 alone.

The 1.4 billion pounds of CO2 produced by flaring equal the emissions from 1.1 million cars or light trucks - roughly an extra 10 cars' worth of emissions per year for every man, woman and child living in the state's largest city, Fargo (population 113,000). While various measures have been developed in the State of North Dakota to curb this waste and require capturing of the natural gas for productive use, as of early 2015 no measure has been enacted.

Check these reports for any relevant information for next response: 3. CITIES: Climate change could cause more blackouts in major U.S. cities -- study 7. ADAPTATION: Global agricultural production to sink due to climate change -- study C - Discuss the social and economic disruptions re: gardening and other activities (snow sports, water sports, etc.) impacted by climate shifts. R - Numerous studies and surveys have measured the value of climate-dependent social and economic activities in Wisconsin. Other studies have estimated the impact of climate change upon those activities. A study measured the impact of higher temperatures on worker productivity and found that productivity drops 3% to 4% for every degree the workplace temperature rises above or fall below the comfort zone (Heal and Park 2013). While air conditioning can minimize this impact for workers in a controlled environment, the costs to businesses, non-profits, institutions and government increase with the need to use more energy for air conditioning or heating. Many forms of outdoor recreation are climate dependent, and they contribute a significant portion of Wisconsin’s total economic health. One national study estimated that in 2011, all forms of outdoor recreation

19 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 nationwide generated $646 billion in direct consumer spending for equipment, travel and services. Outdoor recreation has also long been known to promote improved physical and spiritual health. Wisconsin’s tourism economy includes alpine ski areas and cross country trails from Wilmot on the Fox River near the Illinois border, up to Bayfield on Lake Superior. The ski sector of Wisconsin’s winter seasonal economy produces approximately Snowmobile activities and tourism along Wisconsin’s 25,000 miles of trail produce an estimated $1 billion dollars statewide in economic activity. (http://legis.wisconsin.gov/assembly/czaja/eupdates/Pages/Snowmobiling%20in%20Wisconsin.aspx). One study in 1986 put this figure at $43 million, and another study in 1987 put the figure at 125 million for both equipment and day and overnight outings, so this figure has grown considerably. In years when snowfall is scarce or when snowpack is diminished by warming spells, the economic impact of snowmobiling and skiing drops. The lodging, restaurant, tavern, sporting gods and snowmobiling equipment sectors all are impacted by the rise and fall in climate-dependent snowmobiling and skiing participation. A small but growing sector in the winter recreation industry revolves around the use of snow bikes, whose frames and forks accommodate very wide tires for better stability in most snowy conditions. A 2009 study produced an estimate that bicycling in Wisconsin produces a total economic impact of approximately $1.5 billion, including manufacturing, sales, service and tourism (Kittner 2010). http://host.madison.com/news/local/report-shows-billion-annual-impact-of-bicycling-in- wisconsin/article_526f2c44-0fb0-11df-8c95-001cc4c002e0.html. Deer hunting provides economic benefits of about $1.4 billion, according to a survey completed in 2006 (KIttner 2010). Deer populations can be affected by climate change in the form of increased tick populations and tick-borne disease, heat stress, cold stress, changes in habitat suitability for deer, and changes in cropping patterns that currently provide substantial food for many deer, especially in the farmland zones. Wisconsin DNR teamed up with the University of Wisconsin Nelson Institute for Environmental Studies in late 2007 to form the Wisconsin Climate Change Initiative (WICCI). Several state legislators and their constituents wanted science-based information on potential impacts of climate change in Wisconsin. DNR staff wanted information on impacts to the state's natural resources to use in crafting forward-looking management decisions. WICCI expanded quickly with the addition of researchers, policy analysts, and others from other state and federal agencies; several UW System schools; tribal organizations; businesses; and non-profit organizations. Through various topic-oriented working groups, the WICCI program has identified a Impacts to water sports include hazards posed by toxins produced by excessive concentrations of blue-green algae; changes in precipitation that can lead to reduced lake levels; increased water temperatures that can affect populations and distribution of fish and other aquatic life as well as contribute to excessive rooted aquatic plant growth; http://www.wicci.wisc.edu/water-resources-working-group.php http://www.wicci.wisc.edu/climate-map.php The Wisconsin Department of Health Services, Bureau of Environmental and Occupational Health (BEOH) is developing a Climate and Health program under a federal Building Resilience Against Climate Effects (BRACE) project grant. This program is studying and preparing for anticipated climatic effects on the public's health (WDHS 2014). The overarching goal of this program is to enhance the statewide capacity of DHS to assess, prepare for, and effectively respond to climate and extreme weather events to reduce or prevent negative health effects to Wisconsin's citizens. The Wisconsin BRACE program is seeking climate adaptation strategies that are “based on best practices and scientific knowledge to address health risks related to potential severe weather and climate-driven events.” The Climate and Health Program will explore the state’s ability to predict the public health risk for several climate-

20 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 related risk factors, including: extreme heat, changing precipitation patterns and flooding, drought, impacts on ground water aquifers and surface waters, vector-borne diseases, and winter weather events. In relation to the Climate and Health program, DHS has added to its website a series tool kits for local governments and health professionals to consult in the event of extreme weather-related and other disasters (WDHS 2014). A past Wisconsin state government adiminstration took a major step in the direction of not just responding to climate change, but developing recommended actions and policies to forestall or reduce the degree of climate change that could occur. In July 2008, the Governor’s Task Force on Global Warming released its report “Wisconsin’s Strategy for Reducing Global Warming” (DNR-PSC 008). This report included an extensive list of policy recommendations aimed at reducing state carbon emissions through better efficiency in energy use, an expanded program to generate clean, renewable energy, and incentives for industry, agriculture, forestry and transportation (http://legis.wisconsin.gov/assembly/asm23/news/Hot%20Air/GWTF%20Final_Report.pdf). Researchers have been developing various means to estimate the economic costs of climate change and to then derive an estimate of the costs of emitting greenhouse gasses. One method involves producing a cost estimate for each ton of CO2 emitted by human activity. In developing social cost of carbon as a basis for establishing a carbon “cap and trade” program, the Obama administration in 2014 estimated that each ton of CO2 emitted presents a cost to our economy and environment of about $37. A 2015 paper by two Stanford University researchers proposed that the true cost of releasing greenhouse gases (CO2 equivalent) is about $220 a ton because rising temperatures could badly hinder a nation's economic growth over decades or centuries. This is about five times the Obama administration estimate, but is based upon a different approach of estimating climate impacts. [Combine with or refer to Social Cost of Carbon paragraph] Economic Benefits Note that the project would provide great paying jobs (how much? how many? how long?) for contractors and laborers who would be employed by this project. Service and supply jobs are a spin-off or secondary social- economic benefit. Long term maintenance jobs in Wisconsin would be relatively few. Enbridge has operated in the region since 1950 and pays millions in wages that support the local and regional economy. (How much on a yearly average?) Enbridge provides 800 jobs plus spinoffs. (Are these all local, full time and relatively secure for the foreseeable future? How many would be created by the new 17 miles of pipeline construction and for how long?) The Superior area has long experienced a “youth drain” due to the lack of jobs. This project could help convince some of our young people to stay. Enbridge provides appreciable economic support for local business Enbridge provides financial support for local road repairs. The company also supports local civic activities, some of which strengthen the safety net for local people in need. C - Abandoned lines should be removed to create more jobs. R – Line 3 is proposed to be capped and left in place in order to [save money? Minimize environmental disruption? …]. If the steel in the pipeline were removed and recycled, that act of recycling would support… [ …] {person-days of good-paying jobs and forestall mining of approximately __ tons of iron ore somewhere in the world.

Pipeline Safety Anecdote: “There were 26 accidents involving natural gas, crude oil, gasoline, fuel oil, etc, pipelines. Some were caused by workers digging, others from pipeline failures. But most could not be classified as a “disaster.” Enbridge Pipeline Safety Record and Practices C - Include Enbridge and industry safety record, taking a deep look. Some say Enbridge has a good safety record and others say Enbridge has a bad safety record, with 300 to 800 leaks and spills in the past 10 or 15 years. Safety Record

21 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R – (See Jason Lowey/LS for Waste program, or Darsi Foss) Enbridge is reported to have experienced more than 800 spills in its Lakehead Pipeline System since 1999. [Purported 806 spills/leaks since 1999, as of July 29, 2012: http://griid.org/2012/07/29/enbridge-oil-spill-in-wisconsin-makes-it-the-806th-since-1999/]

The Enbridge website states that their “goal is 100 per cent safe operations and zero incidents and we continually strive towards that objective.” This means they work toward having no spills, leaks or ruptures that could send toxic chemicals and hydrocarbons into the environment. Despite this stated goal, thousands of gallons of harmful substances are released from the company’s pipeline system and storage tanks into the environment each year.

According to Enbridge’s own data, between 1999 and 2010, across all of the company’s operations there were 804 spills that released 161,475 barrels (approximately 25.67 million litres, or 6.8 million gallons) of hydrocarbons into the environment (see table nn).

1).170 This amounts to approximately half of the oil that spilled from the oil tanker the Exxon Valdez after it struck a rock in Prince William Sound, Alaska in 1988. Enbridge also experienced several spills in Wisconsin, including one in 2007 in Clark County, a pipeline rupture in 2007 in Rusk County, and a pipeline rupture in 2012 near Grand March that poured about 1,200 barrels of oil into a farm field and prompted the abandonment and sale of one home. On July 26, 2010, an Enbridge 30 inch pipeline ruptured and leaked oil for 17 hours into Talmadge Creek and the Kalamazoo River and adjacent wetlands in Michigan. This spill of approximately 843,000 gallons of oil prompted the evacuation of some 320 homes. The impact of the spill was magnified by a failure of operating personnel to recognize that a drop in pipeline pressure was in fact a spill, after twice treating the alarms and automated shut-downs as though they were only pressure drops caused by gas bubbles or voids within the oil stream inside the pipeline. Each of those two times the operating team restarted the pipeline pumps, instead of calling for an on-the-ground search for a potential leak. The oil traveled about 35 miles on these waterways from the vicinity of Marshall, MI to just upstream of Kalamazoo, MI, before being contained within approximately 80 miles of Lake Michigan. After 4 years and more than $1 billion dollars spent on clean-up, some speculate that the environmental damage to the Kalamazoo River, Talmadge Creek, and associated wetlands may never be fully repaired. As of the summer of 2014, Enbridge was overseeing the dredging of two sites along (US EPA, 2014). As of November, 2014, the cleanup cost for the Marshall, MI spill has been tallied at more than $1.2 billion. It has been described as “the largest inland oil spill in U.S. history.” The State of Michigan has taken over monitoring and cleaning up the remaining oil that is submerged in the river (Ellison 2014). In a settlement in June, 2015, Enbridge will be responsible for the restoration of damaged natural resource features, including wild rice, other floodplain vegetation, stream habitat, mussels, fish, and other elements. Natural Resource Damage Assessment and Restoration (NRDAR) is the process used by federal, state and tribal governments in jointly seeking this compensation for natural resources injured or destroyed when areas are contaminated with oil or other hazardous substances. In the NRDAR process, government and tribal entities are called "trustees." Compensation sought through the process is then used by the trustees to restore fish, wildlife, and their habitat to pre-spill conditions, and to compensate the public for the lost use and enjoyment of those natural resources. The cost to Enbridge of this restoration is estimate to be at least $62 million (USFWS 2015). The Enbridge Line 5 pipeline variously carrying crude oil and liquid natural gas (LNG) from North Dakota to Sarnia, Ontario via the Straights of Mackinac developed a small leak that was discovered during maintenance on December 8, 2014 (Flesher 2014). The leak was about 90 miles west of the Mackinac Straights. Safety Practices Enbridge provides information on its safety practices in its 2013 report (). IN this report, the company notes that it has spent $4 billion in improvements to its safety and spill response systems. See http://csr.enbridge.com/~/media/www/Site%20Documents/About%20Enbridge/2013%20Operational %20Reliability%20Review.pdf?la=en for additional information from the company. 22 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 C - Car deaths don’t create a call for banning cars, but have led to improvements in vehicle safety, so we need only to make pipelines safer. C - The pipeline is designed conscientiously from an engineering standpoint, so that it will be safe. R – For interstate pipelines such as the proposed Sandpiper pipeline, minimum safety standards are promulgated, administered and enforced by the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation. However, the State of Wisconsin, DNR, uses its authority to hire and direct private inspectors to ensure that construction contractors are meeting pipeline construction permit requirements. This does not entail inspecting welds and other technical aspects, however. This state inspection is limited to environmental protection conditions regarding stream crossings, wetland soil replacement, grading for restoring normal hydrologic patterns, and replacement of vegetation in the construction corridor. For intrastate pipelines, the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation promulgates, administers and enforces only minimum safety standards. States have the option of augmenting these federal requirements with more protective state requirements. Wisconsin, in fact, has the second highest number of state requirements related to pipeline safety (with 75 total measures), second only to New Hampshire. C - Seams are what leak and the problem resides in foreign steel with bad welds in production (from Korea?). C - Are there remote control shut-offs in place along the line? How reliable and effective are they? C - Spills are apparently going to be an ongoing event and they a matter of “when, where and how much?” R - Spills are indeed an occasional occurrence on pipeline systems across the U.S. and the world. In the United States, even with comparatively stringent safety requirements, there occur an average of No one has yet devised a means of preventing spills, but prevention and detection measures that have evolved so far have succeeded in reducing the frequency of spills and leaks relative to the continually increasing number of pipeline miles. Determining an appropriate level of prevention, detection, and spill preparedness appear to most experts on the topic to be the best alternatives to shutting down the transportation by pipeline of petroleum products and other hazardous substances. Enbridge Environmental Stewardship Record Enbridge is a responsible company that cares about environmental protection. One project was delayed 8 months due to a wild iris and a rare goldenrod. Kirtland warbler nest – caring for this nest stopped the hydrostatic testing until protocols were developed to protect the nest and its occupant. Enbridge employees are drug tested (what about contractors?). Pipeline welds are X-rayed. Monitoring is adequate and overall pipeline safety is good. C - Enbridge construction compliance record is poor. R – Enbridge experienced more than 100 wetlands violations during the construction of Line 61 (source other than Sierra - WDNR report on Southern Access?)? C - Enbridge is “restoring [ROW] to original condition.” C - ROW restoration & maintenance is supposed to be completed, to 70% [of soil? original vegetation?], but DNR does not enforce this. Nothing but grass has grown on one landowner’s ROW land for the past 12 years. His land that was once covered in trees and wetlands is now open grasslands. Response: The DNR permit condition regarding Right of Way (ROW) restoration and maintenance requires only certain degree of restoration of public-interest resources (primarily streams, lakes and wetlands). The restoration and maintenance of privately owned upland sites is a matter between the pipeline or utility company and the landowner, and DNR has no authority to impose or enforce conditions regarding these sites. Typically, pipeline companies and utilities want to be able to quickly and easily access their infrastructure corridors in the event of a leak, spill, line break or pole failure. This emergency access is generally best assured by keeping the corridor in grass and shrub cover, which stabilizes soil while affording unimpeded emergency access. Energy Use of Pipeline Transporation Every year, Enbridge and other pipeline companies use large amounts of electricity and other forms of energy to power the large pumps that are used to deliver millions of barrels of crude oil and refined hydrocarbons across 23 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 North America, from Alberta to Midwestern states. According to its own data, in 2008 Enbridge’s Liquids Pipelines Division used more than 6.8 million gigajoules (for Canada-based pipelines only) of electricity to pump, ship and store hydrocarbons. This amount of electricity is the energy equivalent of more than 41 million barrels of oil for one year’s volume of petroleum products (Enbridge 2009). Figures for company-wide energy use are not available, but could be estimated to be at least twice the above figures, because a large portion of Enbridge’s pipelines are in the United States and therefore not included in the Liquids Pipelines Division figures. By comparison, transportation of oil by rail uses ____ equivalent per barrel of oil per mile in delivering oil. Transportation of oil by truck uses ____ equivalent per barrel oil in delivering oil. Spill and Leak Impacts - (Move up above “Flaring Impacts” which needs to be under Secondary) Review impact information developed by North Dakota and Minnesota regarding multi-jurisdictional pipeline projects, including Keystone XL, and include any pertinent information. C - Analyze the cumulative impacts from potential spills from all pipelines in the region, not just those owned and operated by Enbridge. C - In January, 2003, there was a petroleum leak in the Superior area, but no long term damage, and much of the spilled petroleum was recovered. C - Document the present impacts of existing pipelines and of past oil spills on groundwater and surface water resources. C – Note that private water wells in the vicinity of the pipeline are vulnerable to contamination and these wells are not adequately mapped for purposes of monitoring the impacts when a spill occurs. C- Address the fact that the oil pipelines in the Superior area are aging and have experienced leaks under the present (Year 2014) pumping pressure. How can these pipelines withstand the proposed higher pressures, and how much worse would a spill or leak be at the proposed higher pressure than at the current pressure? Quantitatively assess the possible changes to surface water and groundwater that may occur as a result of an oil spill. Keep in mind that the locations of private drinking water wells are not adequately mapped. C - Do not allow the use of dispersants in the event of a spill. Dispersants are toxic by themselves, and have a synergistic effect when combined with oil that can make them up to 52 times more toxic to aquatic life than crude oil alone. R - The Center for Biological and other environmental groups sued the EPA and the U.S. Coast Guard in 2012 for authorizing toxic oil dispersants without ensuring these chemicals would not harm endangered species — including whales, sea turtles and salmon — or their habitats. “One of the most eye-opening lessons of the Deepwater Horizon disaster was just how reliant these spill- response plans were on the use of dispersants and how little we knew about them,” Sakashita said. “We’ve got to step back and fully understand what happens when we release these chemicals into our waters. Otherwise we’re just adding insult to injury during an oil spill” (CBD 2015). Among the most important proposals from the EPA are:  Heightened requirements for testing ecological toxicity and efficacy of dispersants  Better safeguards for human health and disclosure of information about dispersants  Monitoring and reporting on the use and effects of dispersants  Periodic review and revision of oil-spill response plans to ensure environmental protection.

C - Kalamazoo River spill is still not cleaned up after spending $1 billion over three years. At least 320 homes were evacuated there due to off-gassing “something.” What are the ramifications of this kind of “extreme oil” spill or leak, with its chemical cocktail diluent? R - The Kalamazoo River spill of 2010 caused a wide range of environmental impacts in a freshwater riverine environment. Many of these impacts are common to many types of petroleum spills, and are described here, based upon the summary of the Kalamazoo spill monitoring and clean-up.

24 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 T h e E n b r i d g e O i l S p i l l - C a l h o u n C o u n t y , M I

On July 26, 2010, an accident on the Line 6B oil pipeline owned by Enbridge Energy Partners in Calhoun County, Michigan released over 800,000 gallons of crude oil into a tributary of the Kalamazoo River.1 As of August 5, the spill had affected Talmadge Creek and at least 30 miles of the Kalamazoo River downstream of Marshall, MI and the cause of the leak was still unknown. The spill has led to evacuations as well as drinking water, fish consumption and swimming advisories, and containment and cleanup response by the company and a number of agencies.

Following an oil spill on water, the oil undergoes a process termed “weathering,” involving processes such as evaporation of the more volatile chemicals (e.g. benzene), natural dispersion, emulsification, dissolution of certain chemicals into water, sedimentation, and biodegradation.2

Human health concerns with oil spills include prolonged inhalation exposure to crude oil components, which can cause respiratory irritation and headaches, nausea, and other symptoms. In addition to the carcinogen benzene, other chemicals of concern in crude oil include toluene, n-hexane, and hydrogen sulfide.3 These compounds are associated with

Following the spill, recommendations for evacuations had been issued for 30-50 residences near the spill site, due to elevated levels of benzene monitored in the air.4 In addition, the Michigan Department of Community Health issued a precautionary advisory for the Kalamazoo River and vicinity, which includes avoiding (until further notice) consumption of fish of any kind if oiled or smelling of oil, from both Talmadge Creek and the Kalamazoo River down to the west end of Morrow Lake. In addition, the Department recommended against swimming in or touching the water of the river, from I-69 downstream to the west end of Morrow Lake.5

Source: http://www.nwf.org/~/media/PDFs/Regional/Great- Lakes/GreatLakes_MI_Factsheet_KalamazooOilSpill_080910.pdf

The Enbridge spill occurred into Talmadge Creek, a coldwater stream which feeds into the Upper Kalamazoo River just downstream of Marshall, Michigan. Common fish in the creek include mottled sculpin, blacknose dace, and blackside darter.6 The mainstem of the Kalamazoo River from Marshall to Morrow Dam just upstream of the city of Kalamazoo has been classified as “top quality warmwater” fish habitat by the Michigan Department of Natural Resources (now the Michigan Department of Natural Resources and Environment, MDNRE).7 A number of fish species utilize all or part of the affected portion of the Kalamazoo River, including smallmouth and largemouth bass, northern pike, and various suckers, shiners, and other species. Even if fish can swim away from a spill, exposure to some bulk oil can lead to reduced growth rates, and then to increased mortality.8 In addition, fish and other organisms can be exposed to dissolved components of oil (such as polycyclic aromatic hydrocarbons (PAHs)), leading to acute or chronic effects; for example, increased deformities in lake whitefish were associated with increased PAH exposure associated with an oil spill in Wabamun Lake in Canada.9

Some fish species that may be at particular risk from the Enbridge spill include black crappie, bluegill, greater redhorse, pugnose shiner, walleye, and western blacknose dace.10 Several turtle species have been reported in the upper or middle segments of the Kalamazoo River, including the threatened spotted turtle, and Blanding’s and eastern box turtle, both of which are identified as special concern species by the state.11 Adult turtles can be harmed by exposure to oil, and eggs and hatchlings are also at risk. 25 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

A number of other animal species are present in the Kalamazoo River watershed as a whole, including a number of waterfowl that use the Mississippi Flyway (including Canada geese and numerous duck species). In addition, several threatened or endangered water-dependent birds use the watershed, including the common loon, trumpeter swan, osprey, bald eagle, king rail, and Caspian and common terns.12

In addition to potentially suffering acute poisoning from oil ingestion or severe oiling which leads to death, birds are also susceptible to more chronic effects from oil, such as laying of fewer eggs, reduced hatching success, or decreased growth rate in the young.

Mammals present in the watershed that may be at risk from the oil spill include beavers, muskrats and mink.13 Wetlands and other habitat adjacent to the river are also at risk from the oil spill; segments immediately upstream and downstream of Battle Creek in particular have a high abundance of wetlands.14

Summarize pertinent information and correct formatting: T h e E n b r i d g e O i l S p i l l C a l h o u n C o u n t y , M I - Tar s a n d s a n d O i l P i p e l i n e s Remed i a t i o n a n d Restorat ion Response to the oil spill has included involvement of Enbridge, county, state and federal agencies, and U.S. Environmental Protection Agency (USEPA) as the Federal On-Scene Coordinator. Response activities as of August 5 included deployment of over 99,000 feet of containment booms, establishment of 37 containment locations, collection of 53,061 barrels of oil/water mixture in storage, and removal of over 19,028 barrels of oil/ water from the site.21 As of August 5, the U.S. Fish and Wildlife Service had reported that 138 animals had been collected and brought to the wildlife rehabilitation center, including 64 Canada geese and 52 turtles.22 Concerning the ruptured pipeline, the U.S. PHMSA issued a Corrective Action Order on July 28 calling on Enbridge Energy Partners to develop and submit to the agency a restart plan prior to resuming operation of the pipeline, and following approval to restart, operate at reduced pressure. In addition, the order called for submission of an integrity verification and remedial work plan, which would include an evaluation of the remaining portions of the pipeline for any integrity threatening conditions.23 In response to the Removal 26 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Administrative Order from USEPA (requesting an oil recovery and containment plan among others), Enbridge provided to USEPA a work plan on July 29. On July 31, USEPA announced an order of disapproval, including disapproval of the eight component plans. The disapproval order included a number of comments concerning the plan for downstream impacted areas, including the need to reference USEPA Shoreline Contamination Assessment Team recommendations, and Enbridge was to have submitted a revised plan by August 2.24 The Kalamazoo River more broadly has been heavily impacted by other activities. Historic paper production operations downstream of the Morrow Dam resulted in the release of significant quantities of polychlorinated biphenyls (PCBs), and the contaminated sites, a segment of Portage Creek, and the 80-mile stretch of the Kalamazoo River from Morrow Dam to Lake Michigan had been placed on the National Priorities List in 1990 as a Superfund site.25 The same river segment is also designated an Area of Concern under the Great Lakes Water Quality Agreement,26 and a number of fish consumption advisories for several fish species (in particular for PCBs) remain in place in the river.27 Previous restoration objectives had been identified for the Kalamazoo River Superfund site; in addition to eliminating fish consumption advisories and PCB loadings to Lake Michigan, objectives include restoring natural river flow, in-stream movement of fish, and diverse habitats to support various species, including mussels, turtles, mink, otter, and bald eagles.28 Though the new oil spill appears to have been essentially contained above Morrow Dam, the damage from the spill will need to be considered as part of broader restoration objectives for the river. Addressing some damages in the spill area will be particularly challenging, given the potential for some response methods (such as manual oil removal and mechanical removal) to cause high impact in a number of shoreline habitats, including wetlands.29

Following removal and restoration work, monitoring of diverse biota and habitats will be essential; a similarly sized crude oil spill in the Gasconade River in Missouri was associated with decreased biodiversity of macroinvertebrates in backwater sediment habitats, including 18 months after the spill.30 Successful recovery 27 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 of the river will require both well-planned restoration work, protection from new stresses, and comprehensive and long term monitoring.

A spill that occurred February16, 2015, about 18 miles from Gogama, Onatario features 17 derailed cars, some of which ruptured and burst into flame. In addition to a large voulume of hazardous carbon-compound particulate air pollution, the aftermath of the fire is expected to feature large amounts of semi-solid bitumen on the land surface.

The bitumen is toxic and presents to possibility of contamination of nearby or even distant waterbodies when tarry globs are broken apart and washed toward surface waters by heavy rain and snowmelt events. Spilled bitumen also adds toxic compounds to soil. Its tarry nature not only kills nearby susceptible trees when it burns after a derailment or other incident, but there is concern that it can smother trees by coating roots near the surface (CBC 2015). Health Impacts of Common Oil Spill Compounds Several compounds in crude oil and refined petroleum products can have negative effects on human health. The more common of these include, toluene, n-Hexane and hydrogen sulfide. Their effects and exposure limits are as follows: Toluene: Toluene is a clear, colorless liquid with a distinctive smell. Toluene occurs naturally in crude oil and in the tolu tree. It is also produced in the process of making gasoline and other fuels from crude oil and making coke from coal. Toluene is used in making paints, paint thinners, fingernail polish, lacquers, adhesives, and rubber and in some printing and leather tanning processes.  Toluene enters the environment during use of materials that contain it. It can also enter surface water and groundwater from spills of solvents and petroleum products as well as from leaking underground storage tanks at gasoline stations and other facilities.  When toluene-containing products are placed in landfills or waste disposal sites, the toluene can enter the soil or water near the waste site.  Toluene does not usually stay in the environment long.  Toluene does not concentrate or buildup to high levels in animals. Toluene may affect the nervous system. Low to moderate levels can cause tiredness, confusion, weakness, drunken-type actions, memory loss, nausea, loss of appetite, and hearing and color vision loss. These symptoms usually disappear when exposure is stopped. Inhaling High levels of toluene in a short time can make you feel light-headed, dizzy, or sleepy. It can also cause unconsciousness, and even death. High levels of toluene may affect your kidneys. Some studies in animals suggest that babies may be more sensitive than adults. Breathing very high levels of toluene during pregnancy can result in children with birth defects and retard both mental abilities and growth. Researchers do not know if toluene harms the unborn child if the mother is exposed to low levels of toluene during pregnancy. Discharges, releases, or spills of more than 1,000 pounds of toluene must be reported to the National Response Center. EPA has set a limit of 1 milligram per liter of drinking water (1 mg/L). The Occupational Safety and Health Administration has set a limit of 200 parts toluene per million of workplace air (200 ppm) (ATSDR 2014). Medical testing can detect toluene in arterial blood within 10 seconds of inhalation exposure. The federal NHTSA describes toluene as a chemical that “is highly lipid soluble and accumulates in adipose tissue, tissues with high fat content, and highly vascularized tissues. Highest concentrations are found in the liver, kidney, brain and blood. The initial half-life in whole blood averages 4.5 hours, (range of 3-6 hours), with a terminal

28 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 phase half-life of 72 hours. The half-life in adipose tissue ranges from 0.5-2.7 days, increasing with amounts of body fat. Approximately 80% of a dose is metabolized in the liver (NHTSA 2015). n-Hexane: n-Hexane is a chemical made from crude oil. Pure n-Hexane is a colorless liquid with a slightly disagreeable odor. It is highly flammable, and its vapors can be explosive. Pure n-Hexane is used in laboratories. Most of the n-Hexane used in industry is mixed with similar chemicals called solvents. The major use for solvents containing n-Hexane is to extract vegetable oils from crops such as soybeans. These solvents are also used as cleaning agents in the printing, textile, furniture, and shoemaking industries. Certain kinds of special glues used in the roofing and shoe and leather industries also contain n-Hexane. Several consumer products contain n-Hexane, such as gasoline, quick-drying glues used in various hobbies, and rubber cement.

 n-Hexane enters the environment during is manufacture and use, such as vehicle fueling.  It evaporates very easily into the air where it is broken down in a few days.  It dissolves only slightly in water.  Most of n-hexane spilled in water will float on the surface where it evaporates into the air.  If n-hexane is spilled on the ground, most of it will evaporate before it can soak into the soil.  n-Hexane is not concentrated by plants, fish, or animals.

The only people known to have been affected by exposure to n-hexane used it at work. Breathing large amounts caused numbness in the feet and hands, followed by muscle weakness in the feet and lower legs. Continued exposure led to paralysis of the arms and legs. If removed from the exposure, the workers recovered in 6 months to a year. We don't know if the effects seen in children would be different than those seen in adults. Sometimes older children intentionally inhale household chemicals containing n-Hexane, especially quick- drying glues and cements, in an attempt to get "high." This has caused paralysis of the arms and legs of teenagers in the U.S. and Europe.

In laboratory studies, animals exposed to high levels of n-hexane in air had signs of nerve damage. Some animals also had lung damage. In other studies, rats exposed to very high levels of n-hexane had damage to sperm-forming cells. The EPA requires that spills or accidental releases of 5,000 pounds or more of n-hexane be reported to the EPA.

The National Institute of Occupational Safety and Health (NIOSH) recommends exposure to no more than 50 parts per million (ppm) in workplace air. The Occupational Health and Safety Administration (OSHA) has set a permissible exposure limit of 500 ppm for n-hexane in workplace air (ATSDR 2014).

Hydrogen sulfide: Hydrogen sulfide is a colorless, flammable, highly toxic gas. It is shipped as a liquefied, compressed gas. It has a characteristic rotten-egg odor that is detectable at concentrations as low as 0.5 ppb. Hydrogen sulfide is produced naturally by decaying organic matter and is released from sewage sludge, liquid manure, sulfur hot springs, and natural gas. It is a by-product of many industrial processes including petroleum refining, tanning, mining, wood- pulp processing, rayon manufacturing, sugar-beet processing, and hot-asphalt paving. Hydrogen sulfide is used to produce elemental sulfur, sulfuric acid, and heavy water for nuclear reactors.

Inhalation is the major route of hydrogen sulfide exposure. The gas is rapidly absorbed by the lungs. Inhalation of high concentrations of hydrogen sulfide can produce extremely rapid unconsciousness and death.

The odor threshold (0.5 ppb) is much lower than the OSHA ceiling (20 ppm). However, although its strong odor is readily identified, olfactory fatigue occurs at high concentrations and at continuous low concentrations. For this reason, odor is not a reliable indicator of hydrogen sulfide's presence and may not provide adequate

29 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 warning of hazardous concentrations. Hydrogen sulfide is slightly heavier than air and may accumulate in enclosed, poorly ventilated, and low-lying areas.

Children inhaling the same levels of hydrogen sulfide as adults may receive larger doses because they have greater lung surface area:body weight ratios and increased minute volumes:weight ratios. In addition, they may be exposed to higher levels than adults in the same location because of their short stature and the higher levels of hydrogen sulfide found nearer to the ground. Children may be more vulnerable to corrosive agents than adults because of the relatively smaller diameter of their airways.

Hydrogen sulfide is a mucous membrane and respiratory tract irritant; pulmonary edema, which may be immediate or delayed, can occur after exposure to high concentrations. Hydrogen sulfide also irritates skin, eyes, mucous membranes, and the respiratory tract. Pulmonary effects may not be apparent for up to 72 hours after exposure. Exposure to the liquified gas can cause frostbite injury.

Symptoms of acute exposure to hydrogen sulfide include nausea, headaches, delirium, disturbed equilibrium, tremors, convulsions, and skin and eye irritation. Acute exposure to hydrogen sulfide can cause inhibition of the cytochrome oxidase enzyme system resulting in lack of oxygen use in the cells. Anaerobic metabolism causes accumulation of lactic acid leading to an acid-base imbalance. The nervous system and cardiac tissues are particularly vulnerable to the disruption of oxidative metabolism and death is often the result of respiratory arrest. Children do not always respond to chemicals in the same way that adults do. Different protocols for managing their care upon exposure may be needed.

Central Nervous System injury is immediate and significant after exposure to hydrogen sulfide. At high concentrations, only a few breaths can lead to immediate loss of consciousness, coma, respiratory paralysis, seizures, and death. CNS stimulation may precede CNS depression. Stimulation manifests as excitation, rapid breathing, and headache; depression manifests as impaired gait, dizziness, and coma, possibly progressing to respiratory paralysis and death. In addition, decreased ability to smell hydrogen sulfide occurs at concentrations greater than 100 ppm.

Respiratory - Inhaled hydrogen sulfide initially affects the nose and throat. Low concentrations (50 ppm) can rapidly produce irritation of the nose, throat, and lower respiratory tract. Pulmonary manifestations include cough, shortness of breath, and bronchial or lung hemorrhage. Higher concentrations can provoke bronchitis and cause accumulation of fluid in the lungs, which may be immediate or delayed for up to 72 hours. Lack of oxygen may result in blue skin color.

Children may be more vulnerable to corrosive agents than adults because of the relatively smaller diameter of their airways. Children may also be more vulnerable to gas exposure because of increased minute ventilation per kg and failure to evacuate an area promptly when exposed.

Cardiovascular - High-dose exposures may cause insufficient cardiac output, irregular heartbeat, and conduction abnormalities.

Renal - Transient renal effects include blood, casts, and protein in the urine. Renal failure as a direct result of hydrogen sulfide toxicity has not been described, although it may occur secondary to cardiovascular compromise.

Gastrointestinal symptoms may include nausea and vomiting.

30 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Dermal - Prolonged or massive exposure may cause burning, itching, redness, and painful inflammation of the skin. Exposure to the liquified gas can cause frostbite injury.

Ocular - Eye irritation may result in inflammation (i.e., keratoconjunctivitis) and clouding of the eye surface. Symptoms include blurred vision, sensitivity to light, and spasmodic blinking or involuntary closing of the eyelid.

Respiratory - Inflammation of the bronchi can be a late development. Survivors of severe exposure may develop psychological disturbances and permanent damage to the brain and heart. The cornea may be permanently scarred.

Prolonged skin or eye contact with hydrogen sulfide, even at relatively low levels, may result in painful dermatitis and burning eyes. Direct contact with the liquefied gas can cause frostbite. Absorption through intact skin is minimal.

Standards and Guidelines OSHA ceiling = 20 ppm

OSHA maximum peak = 50 ppm (10 minutes, once, no other exposure)

NIOSH IDLH (immediately dangerous to life or health) = 100 ppm

AIHA ERPC-2 (emergency response planning guideline) (maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action) = 30 ppm (ATSDR 2014).

(Continue the above with relevant effects summary information) C - What would be the impacts to Lake Superior from a loading or shipping spill? Consider the heavy nature of tar sands crude and its propensity to sink the bottom of a water body. It has been shown that tar sands crude sinks in water, where it will be extremely difficult to clean up, especially in deeper water. What are the impacts of that in the short term and long term? What kind of cleanup technique is going to succeed at cleaning that up? C - Some 200,000 tourism jobs [in WI or Lk Superior watershed?] rely upon clean water and healthy lakes and would be jeopardized by a major spill or leak. R – Several thousand jobs in Wisconsin, and many more in Minnesota, Michigan and Ontario rely in whole or in part on the unpolluted waters, wetlands and shorelands of Lake Superior, its tributaries, and connected inland lakes. These include jobs in manufacturing, shipping, drinking water supply, other industries, agriculture, tourism, and local recreation. Economically and socially vital tourism and recreation activities supported by Lake Superior and its watershed include beach strolling, wildlife viewing, biking, birding, boating, canoeing & kayaking, scenic cruises, fall color tours, community festivals, golfing, hiking, hunting & fishing, visiting islands, exploring public parks, scuba diving, other water sports, winter activities including ice fishing and skiing, historical, arts and cultural exhibits, museums and events, visiting historic sites and lighthouses, exploring shipwrecks. (summarize economic impact of the lake dependent activities and note those that could be impacted by pipeline construction or operation.) C - Impacts of spills upon Lake Superior need to be evaluated in light of the Great Lakes Water Quality Agreement between the United States and Canada, and notify other parties to this agreement, as required under Article 6.

31 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R - The Enbridge Line 5 pipeline variously carrying crude oil and liquid natural gas (LNG) from North Dakota to Sarnia, Ontario via the Straights of Mackinac developed a small leak that was discovered during maintenance on December 8, 2014. The leak was about 90 miles west of the Mackinac Straights. In evaluating spill and leak impacts, examine all media (air, soil, water) and life forms (bacteria, plants and animals). C - Require a performance bond to guarantee there will be sufficient funds for a total clean-up. R - Are bonds or other financial assurances required of pipeline operators (?) – (Check with Ben or Josh) Summarize for impacts section: FishVis forecasts climate change effects on fish Posted on Jan 2, 2015 at 8:29 a.m. By Melissa Barsamian Wisconsin Public Radio A group of researchers from the Wisconsin Department of Natural Resources helped invent an online climate change tool called FishVis.

FishVis is an online site for the public. John Lyons fisheries research supervisor for the Wisconsin Department of Natural Resources, said FishVis looks at 13 possible climate change scenarios that may affect fish numbers. The site covers Wisconsin waters, the Great Lakes and beyond. "Some scenarios say it’s going to get a lot warmer. Other scenarios say it’s going to get a little warmer. Some scenarios say it’s going to be wetter and other scenarios say it’s going to be dryer," said Lyons. "Because there is some uncertainty about exactly how some things are going to play out. This allows you to look at some of those different possibilities and look at how the fish might respond." Lyons said all scenarios agree the climate is getting warmer. He said that may not be a bad thing. "There are some projections that if Lake Superior gets warmer, which it appears to be doing, that that may actually be beneficial for certain species that prefer somewhat warmer water," said Lyons. "Things that are in the near shore area like walleye or yellow perch, or things that you might find in the harbor around Duluth/Superior or over in Chequamegon Bay, those are things that the warming temperature might actually benefit them." Lyons said he hopes FishVis will be used as a teaching tool for public universities. "I think this is a very important step to get beyond just ‘Oh it’s going to get warmer.’ What does that mean? What does that imply? And, what is going to be the consequences for, in this case, stream and river ecosystems?" said Lyons. Grant money and roughly $275,000 from the U.S. Fish and Wildlife Service helped fund the website. Lyons said they hope to unveil the website (http://wimcloud.usgs.gov/apps/FishVisDev/FishVis.html#) soon. in Wisconsin? C - Examine “downstream” projects and their individual and cumulative impacts, including Line 61; Line 5 to Michigan; Line 3 tar sands crude. C - We know petroleum products spills cause respiratory and gastro-intestinal illness. We do not know the long term impacts of breathing hexane, benzene and similar compounds – We need to know what are the potential impacts of all these substances. C - Statistically, about 60% of an oil spill remains in the environment. What are the impacts of that in the short term and long term? C - “Inert” ingredients can be worse than what may be stated as “active.” Consider impact of “worst case” spill. Look at the complete picture and everyone who is impacted. C - We don’t want bad things to happen but have to live with risk [when the odds favor a greater benefit]

32 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 C - “DNR is charged with protecting flora and fauna” and “taking care of risk.”

Cumulative Impacts C - WEPA requires an evaluation of all cumulative impacts. C - Evaluate the cumulative (climate, ecological and economic?) impact of the entire Enbridge pipeline network. R - Enbridge describes itself as Canada’s largest transporter of crude oil. The company has approximately 15,294 miles of pipelines that delivering on average over 2.2 million barrels per day of crude oil and petroleum liquids. Enbridge notes that it exports 69 per cent of Western Canadian oil, which amounts to about 13 per cent of U.S. daily crude oil imports. On a daily basis, Enbridge is the largest single distributor of oil into the U.S. They ship via pipeline more than 100 types of refined and raw petroleum and natural gas products. (http://www.enbridge.com/InYourCommunity/PipelinesInYourCommunity/~/media/www/Site %20Documents/In%20Your%20Community/PublicAwareness/canada/EmergencyResponderAthabasca.pdf). Enbridge received a Presidential Permit for the Alberta Clipper tar sands crude pipeline in 2008. The permit was for the project to run 450,000 barrels per day—not 570,000 barrels per day as Enbridge now (2014) proposes. Pumping 120,000 more barrels per day presents significant additional risks that must be examined. The current permit does not stipulate that the company is allowed to expand the project, and the State Department must conduct a new environmental assessment of the potential impacts of such an expansion on the climate, the local ecosystems, and public health. Estimating the climate impacts of all these energy and other products is a large and complex task. There are a large number of published studies that do provide insight into the links between increase burning of fossil fuels such as tar sands derived oil, impacts to climate change, with attendant impacts on human health and the stability of ecological processes. [Summarize and cite original study or article]: Climate change accelerates the spread of asthma Brittany Patterson and Manon Verchot, E&E reporter. Published: Thursday, April 30, 2015. http://www.eenews.net/climatewire/stories/1060017690 Climate change set to take major toll on economy and children's health, experts warn. Manon Verchot, E&E reporter. Published: Tuesday, May 12, 2015 http://www.eenews.net/climatewire/2015/05/12/stories/1060018385 C - You need interstate cooperation in the review of this and similar projects because they have a scope of impacts that is very broad on a geographic scale, with complex interactions across many environmental, social and economic topics. C - Consider Line 3 as being integral to the proposed Calumet/Elkhorn project to facilitate shipping by freighter, and evaluate potential shipping spill impacts as a cumulative impact. DNR has already acknowledged that this project is indeed integral to the Sandpiper project. C – [Energy] Transportation infrastructure was set up to IMPORT oil. Now we have sources in North Dakota and Alberta that are far from refineries. There is no government oversight re: energy infrastructure and such a review can’t be done by any one state. States need to band together to provide a thorough look at the big picture regarding energy supply, demand and impacts. R – The energy “map” of the United States is indeed expansive and complex. However, this analysis will for the most part be limited to the impacts posed by those segments of the proposed project within Wisconsin, and to the impacts upon Wisconsin. Impacts created or affected by activities in other states can also affect Wisconsin, and those will be outlined in less detail. The federal legislative and executive branches have the lead responsibility for setting national energy policy, including oversight of many facets of energy development and distribution, as implemented by the Department of Energy and other executive agencies. The mission of the Energy Department is ”to ensure America’s security and prosperity by addressing its energy, environmental and nuclear challenges through transformative science and technology solutions.” However, while at least three energy policy acts have been passed by Congress and the President, nowhere does there exist a cohesive, comprehensive, all-encompassing national energy policy. 33 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Secondary Impacts C - The Calumet/Elkhorn storage and shipping proposal appears to be an integral part of the Sandpiper project. What will be the short-term and long-term health risks of having two new 5-story oil storage tanks potentially leaking vapors next to a residential neighborhood? C- Will this additional flow of oil contribute to an increase in the volume of oil that is refined at the Calumet refinery in Superior, causing an increase in harmful air emissions? Add – The operation of this pipeline would serve to promote additional hydro-fracking beyond current (early 2015) levels, with attendant costs and benefits in oil production areas. This would increase the likelihood of increasing the impacts of the fracking process. These impacts can include any combination of groundwater (including scarce Western irrigation water) pollution via injection into disposal wells, release of waves or swarms of small to moderate earthquakes and tremors due to injection of wastewater into disposal wells in fault zones [check-does this apply to ND?], ozone and other air pollution due to release of methane from improperly sealed wells, damage to local roads and state highways from transportation of heavy drilling rigs, increased costs for law enforcement, traffic management, school expansions, educational staff, recreation, affordable housing subsidies, mental health services, and other public services (ENPF 2015, CFBD 2015) necessitated by a large influx of oil field workers. On the other hand, an injection of high-salaried oil workers would be able to support an increase in a wide variety of new service jobs and provide other local economic benefits, depending on income tax policies and other factors. Boom and bust cycle in frac sand mining Since the arrival of a mine that supplies sand to hydraulic fracturing sites in distant shale fields, this tiny township has gained a new dump, recycling center, snowplow and salt shed. Plans for a community garden are underway in a neighborhood across the street from the plant. Perched atop a pair of railroad underpasses, Unimin Corp.'s Tunnel City silica extraction center last year began sending carloads of fine, white sand to energy producers in Pennsylvania, North Dakota and Texas. Under the terms of Unimin's development contract, the company owes Greenfield 15 cents on the first million tons of sand it ships out of Tunnel City and 10 cents after that. In 2014, the mine's first year of operation, Unimin paid out $222,019 to the community. "For our township, it's a gift from heaven," said Greenfield Clerk Susie Zillmer. But those funds are tied to the sand mine's performance. And while demand for proppant per individual well is on the rise, it won't offset the drop-off in rig count and backlog of uncompleted wells spurred by declining oil prices, according to an April 25 note from Moody's Investors Service. Those wells are likely to remain unfinished until the cost of completions drops or crude prices recover, the analysts found. Wisconsin has 58 inactive sand extraction sites -- a number almost equivalent to its 63 active mines, according to data from the state Department of Natural Resources. There is substantial interest in bringing more facilities online, but the oil price slump has made it difficult to get those projects off the ground, said Eric Bott, director of environmental and energy policy for Wisconsin Manufacturers & Commerce. News of layoffs in the sand sphere has been minimal so far. Last month, U.S. Silica notified the state Department of Workforce Development that on July 15 it plans to let go of 30 workers at its Sparta, Wis., location. The company is also aiming to buy up some of the market share it expects will soon be vacated by shuttered mines -- but that could take some time (King 2015). Groundwater contamination from hydraulic fracking fluids Hydraulic fracturing can contaminate drinking water but has not caused "widespread" impacts, U.S. EPA found in a highly anticipated study released today. The landmark findings, published in a final draft still subject to public comment and peer review, assessed the potential "life-cycle" effects of fracking -- from water acquisition to injection to wastewater management -- and identified vulnerabilities in the process that have led to contamination of surface water and groundwater in several cases. "Of the potential mechanisms identified in this report, we found specific instances where one or more mechanisms led to impacts on drinking water resources, including contamination of drinking water wells," EPA

34 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 said in an executive summary. "The number of identified cases, however, was small compared to the number of hydraulically fractured wells." The report upsets the industry line that fracking has never contaminated drinking water but concludes that the evidence does not indicate "widespread, systemic impacts on drinking water resources in the United States." Relationship to large increase in small earthquakes in fracking fluid disposal well zones A number of studies have concluded that there is likely a causal relationship between disposal of fracking fluid in deep disposal wells and the significant occurrence of relatively low energy earthquakes in several states, including Oklahoma, Texas, Kansas, and New Mexico [check re: PA? OH? ND? CA?]. At least one study concluded that in the long run, these quakes may offer a benefit in serving to release tension in geologic fault zones in a manner that lessens the likely magnitude of future earthquakes in the vicinity of disposal wells. Climate and other ecological impacts of tar sands development “The controversial proposed Keystone XL Pipeline put Canada’s vast carbon-laden tar sands on the map for many Americans, with its builders promising that it would carry 800,000 barrels of petroleum per day from Alberta’s tar sands to oil refineries in Texas. But a group of 100 scientists on Wednesday called for a moratorium on further oil sands development, saying it isn’t compatible with stabilizing the climate and meeting greenhouse gas emissions reductions targets. “We shouldn’t be doubling down or quadrupling down on the tar sands going from 2 million barrels per day to four, six, eight as industry is calling for by proposing expansions and proposing pipelines,” Simon Fraser University energy economist Mark Jaccard said. Many scientists, environmental groups and President Obama have voiced concern about the effect of tar sands, or oil sands, on the climate. The U.S. State Department concluded that oil sands are more than 17 percent more carbon-intensive to extract than the average barrel of oil (does this include processing, and if not, does that add more carbon intensity?). The Canadian Association of Petroleum Producers announced Tuesday that oil sands will account for most of a 43 percent increase in Canadian crude oil production through 2030. Production is expected to grow from 3.7 million barrels per day to 5.3 million barrels. Of those, 4 million barrels will come from oil sands” (Magill 2015). Wetland Impacts and Mitigation C - Describe the impacts of wetland fill and hydrologic alteration, and the actions needed to avoid and mitigate these impacts. R – Wetland protections have been for many years a routine part of permitting pipeline and other linear energy projects. Conditions are placed on these energy infrastructure projects that help minimize long-term loss of wetland functions and values. Permit conditions require that _(See Ben’s response early Feb.)__ . During construction, the Department contracts with independent construction monitors who inspect construction and restoration work to ensure that it meets all applicable permit conditions. C - Describe the successes and failures or shortcomings of wetland mitigation, including to what extent lost wetland values can be replaced through mitigation. R – Wisconsin DNR regulates construction for projects that have potential wetland impacts according to requirements in two state administrative rules: NR 103 (state water quality standards) and NR 350 (requirements for mitigation projects). A 2005 DNR internal report to the legislature (http://intranet.dnr.state.wi.us/int/water/fhp/wms/mitigation/index.shtml) was submitted after only three years of implementing new mitigation requirements, so does not contain sufficient data to use in evaluating the success of mitigation. This program combines the principle of first avoiding and minimizing wetland losses. Mitigation for unavoidable losses is required to take place at a ratio of 1:1 within the same major basin where the regulated project is proposed, if at all possible (see: http://dnr.wi.gov/water/basin/). Mitigation outside that basin requires a larger acreage of wetland mitigation, using a ratio of 1:1.5. In addition to focusing on mitigating wetlands losses “onsite” (within ½ mile of the wetland loss), DNR has approved several sites in the state for use as “mitigation banks” where restored or enhanced wetlands may be used to mitigate the unavoidable loss of

35 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 wetlands. Where practicable, mitigation needs to occur using the same wetland type (among 11 different types) as the wetland type(s) that would be lost. However, DNR staff acknowledge that wetland quality at mitigation sites has generally been only moderate, so lost wetland functions are not fully replaced. DNR is working to help ensure that future mitigation projects will replace both the functions and the quality that was provided by the wetlands being lost to permitted development. In the event of a spill into a wetlands area, (See Kalamazoo)… Secondary or Indirect Impacts Evaluate whether this project would induce or encourage the use of more carbon fuels, thereby contribute to additional carbon loading of the atmosphere, thereby contributing to climate change. C - 95% of the scientific community accepts climate change as an ongoing, anthropomorphic event. R – According to Wisconsin DNR administrative staff and managers, global climate change is a topic “of some dispute on the global stage.” However, DNR provides no factual basis for this assertion. To the contrary, the level of agreement among researchers regarding most issues surrounding climate change and the role of greenhouse gasses is extremely high. Further, there are many actions that society can take to lower human- generated GHG emissions that represent a “win-win” outcome, even to those who are fixated on economic costs of meaningful and effective action. This is because any energy conserving measures free up money for businesses to expand and create new jobs, and for working people to direct toward non-fossil fuel purchases . Meanwhile, the year 2014 has been acknowledged to be the warmest year on record, based on global average temperatures at a multitude of data collection sites all over planet Earth. A study sponsored by the Carnegie Endowment for International Peace (CEIP 2015) evaluated the lifecycle greenhouse gas emissions for a wide and representative variety of crude oils from around the world. This study found that that the crudes oils to be shipped by the proposed Sandpiper pipeline are among the top climate change gas emitters among all the oil source in the world. Tar sands crude (often referred to as “syncrude”) requires a great deal of fossil energy for its production and processing, and leaves a large portion as high-carbon residue, such as petcoke (see section _ on petcoke emissions). Bakken oil production results in the emission of large qualtities of natural gas (methane), a greenhouse much more potent than CO2. C - This project may lead to an oversupply of oil and create a bottleneck at Superior, which would drive a demand for shipping crude oil across the Great Lakes. Is this a possibility (and refer to the lake shipping impacts listed above) Impact on renewable energy industry that we have been promoting? R – Whether a surplus of oil would develop at Superior depends on a combination of several factors. First, if the proposed Keystone XL pipeline is built, it would likely divert significant quantities of oil from Alberta and North Dakota to the Gulf of Mexico. Next, Enbridge is proposing to expand the capacity of its existing Line 61 by increasing its operating pressure. This would enable transporting much more oil south from Superior than is currently transported. This expansion alone will / will not enable the additional oil from Sandpiper to be shipped south via Line 61, rather than using Lake Superior tanker ships. C - Discuss the health impacts of an expansion of oil refinery pollutants in the Superior area. The area already has a high rate of cancer, and too much secrecy regarding pollutants, pollutant levels and health impacts. Note whether additional refining capacity, roadway capacity, or lake shipping terminals or docks will be required to be constructed. C- Other means of transporting also carry risk. Describe impacts of trucking and rail as well. R – Moving crude oil by rail in the United States is a relatively rare method of transportation. Trucks are used to move crude oil primarily from isolated wells to storage tanks that are generally located at the terminus of either a pipeline or a rail line. U.S. railroad puts moratorium on new oil tank cars Posted Nov. 20th, 2014 Oil shippers not happy | BNSF says it hopes to reduce complaints from other sectors about oil cars causing rail congestion and delays NEW YORK/CALGARY (Reuters) — IN November, 2014, BNSF Railroad told some customers that they cannot add new oil tank cars to its system until some time in 2015. Oil shippers seeking to add as many as a 36 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 dozen new crude oil trains to BNSF’s lines, which is more than 1,000 tank cars, have been “blocked out,” one of the sources said. “They can keep however many they are running, but cannot bring on any more.” The moratorium on new cars, which customers were informed of in recent weeks, is BNSF’s latest effort to avoid worsening congestion on its rail network amid record freight traffic and growing scrutiny from lawmakers and federal regulators upset by months of complaints over poor service and delays. Persistent delays in oil train shipments to the U.S. East Coast are beginning to ease, providing relief to refiners. Preventing shippers from putting more rail cars onto the network may help prevent overloading the system, but it is also irritating some shippers who are still racing to tap into the growing volume of oil from North Dakota. More than 9,000 new tank cars are expected to roll off production lines this quarter. BNSF’s efforts come just as the nation’s rail system faces what could be its biggest-ever test as farmers start shipping a record harvest of corn and soybeans, while at the same time winter weather threatens to slow down operations. “A lot of grain is still backed up that they have to clear,” said one of the people familiar with the matter. The informal moratorium “means the volumes on rail are somewhat being forced lower. There’s demand and capacity, but the railroads just cannot keep up.” Mike Trevino, a BNSF spokesperson, said he would not describe the company’s actions as a moratorium. Instead, the company is working to manage freight volumes that have reached record highs for each of the past eight weeks. “There’s a lot of volume, and we are going to evaluate new train starts,” he said. “Before we add incrementally more business to the network, we need to see if the network can handle it.” Martin Cej, a spokesperson with Canadian Pacific Railway, said the company has no plans at this point to issue a similar moratorium. “CP is always looking at opportunities to pick up new business as it improves service for existing customers,” Cej said when asked if the company has room to handle some of the business BNSF may lose. BNSF, once known as Burlington Northern Santa Fe, has taken the heaviest criticism over the system-wide deterioration in North American rail service this year, including a sharp fall in rail speeds and longer waiting times at terminals. Railroads blamed record freight and last winter’s brutal weather. Farmers, ethanol producers and refiners said rail operators were failing to keep up with demand for their service, often blaming the boom in oil-by-rail trade. Preventing customers from adding new rolling stock to its 51,000 kilo-metre network may help BNSF avoid further complaints that its locomotives are not moving freight quickly enough from one point to another, as it is required to do. Meanwhile, new tank cars are rolling off production lines in growing numbers to meet demand for oil shipments. A record 9,235 were delivered in the third quarter, according to Railway Supply Institute data. East Coast refiners, which are the nation’s largest consumers of Bakken crude oil from North Dakota, have been creative in finding ways around the moratorium, an industry source said. Some have cut deals with traders to divert trains from the Gulf Coast, where new pipelines have come online, to the East Coast, one of the sources said. “There’s certainly demand for additional rail cars on the East Coast, and it’s certainly been frustrating for some,” said a source. Faced with a limited number of rail cars on the BNSF system until January 2015, some refiners are exploring using different rail carriers, such as Canadian Pacific (CP), he said. For the moment, operations on the U.S. rail network are improving. BNSF recently placed a new double track line into service in northwestern North Dakota, which connects Minot and Williston. It is part of a US$5.5

37 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 billion plan to improve service along the Great Northern Corridor from the Pacific Northwest to Chicago, which is the most affected part of the network. The company has also hired more than 400 new employees in North Dakota, Trevino said. Shipments of crude by train are making round trips from North Dakota to the East Coast in 18 to 19 days, down from 23 to 24 days over recent months, according to one source involved in the oil-by-rail trade. A trader said the investments in tracks and manpower have helped, but “we’re still far from where we were in the summer of 2013, when it all started going downhill.” However, BNSF may face a new problem once it begins adding cars back on to the system, which is expected early next year.“I would not want to be the guy at BNSF having to decide who comes first,” said one of the sources. C - Processing tar sands crude leaves enormous volumes of refinery coke. Koch Industries wants to ship this to China for burning as fuel, but the pollution will return to us. R – In late summer 2013, then-Detroit Mayor Dave Bing ordered the removal of large piles of petroleum coke (“petcoke), from land along the Detroit River. Petcoke is a by-product of refining tar sands oil into gasoline and other products. The same problem has occurred in the Chicago area where refineries are producing even larger amounts of the stuff (http://freethoughtblogs.com/dispatches/2013/10/17/the-petroleum-coke-problem/) Oct. 17, 2013. See - July 2 update re: closing down one of two Chicago area sites. Edit sections like this to make them more succinct and neutral: The Canadian tar sands have been called the “most environmentally destructive project on earth”, with good reason. Extracting tar sands bitumen from under the boreal forests of Alberta, Canada requires huge amounts of energy and water. It has cleared vast tracts of forest, left scars on the land that are visible from space and threatened the health and livelihoods of indigenous First Nations communities across the region. It is a well established fact that full exploitation of the tar sands is a grave threat to the climate. Emissions from tar sands extraction and upgrading are between 3.2 and 4.5 times higher than the equivalent emissions from conventional oil produced in North America.On a lifecycle basis, the average gallon of tar sands bitumen derived fuel has between 14 and 37 percent more greenhouse gas emissions than the average gallon of fuel from conventional oil. But as bad as these impacts already are, existing analyses of the impacts of tar sands fail to account for a byproduct of the process that is a major source of climate change causing carbon emissions: petroleum coke – known as petcoke. Petcoke is the coal hiding in North America’s tar sands oil boom. Petcoke is like coal, but dirtier. Petcoke looks and acts like coal, but it has even higher carbon emissions than already carbon-intensive coal.  On a per-unit of energy basis petcoke emits 5 to 10 percent more carbon dioxide than coal.

 A ton of petcoke yields on average 53.6 percent more CO2 than a ton of coal.  The proven tar sands reserves of Canada will yield roughly 5 billion tons of petcoke – enough to fully fuel 111 U.S. coal plants to 2050.  Because it is considered a refinery byproduct, petcoke emissions are not included in most assessments of the climate impact of tar sands or conventional oil production and consumption. Thus the climate impact of oil production is being consistently undercounted. Industry observers liken petcoke production from tar sands crude to turning American refineries into carbon- intensive coal factories for several reasons:

 There is 24 percent more CO2embedded in a barrel of tar sands bitumen than in a barrel of light oil.  15 to 30 percent of a barrel of tar sands bitumen can end up as petcoke, depending on the upgrading and refining process used. 38 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015  Of 134 operating U.S. refineries in 2012, 59 are equipped to produce petcoke.  U.S. refineries produced over 61.5 million tons of petcoke in 2011 – enough to fuel 50 average U.S. coal plants each year.  In 2011, over 60 percent of U.S petcoke production was exported (Stockman 2013). Industry analysts tout the many uses of petcoke as an often less costly replacement for clenser burning industrial fuels (JCI 2005). China currently burns __ tons of coal and __ tons of petcoke, and much of China currently suffers severely from air pollution resulting from burning these and other fuels. Air research has demonstrated that a significant volume of this air pollution crosses the Pacific Ocean with weather systems, bringing this pollution to places that include southern California. In California, Chinese-origin air pollution makes it much more difficult for regions such as the Greater Los Angeles region to achieve air quality goals. Minnesota researchers have discovered that about 25% of the mercury accumulated by common loons originates at coal-burning facilities in China, meaning many other co-pollutants are traveling to Minnesota and beyond. Therefore, sending more of this by-product of petroleum refining to China will necessarily mean more air pollution in the U.S. R – Processing of tar sands petroleum has numerous other impacts on the human and other facets of the natural environment. These include the proliferation of new pipelines, destruction of Boreal forest and wetland habitats, pollution of surface and groundwater, air pollution, burning enormous quantities of relatively clean natural gas, and health damage to people living in the vast region of Saskatchewan where the prime tar sands deposits lie beneath the land surface. The Line 6B oil pipeline, where the leak occurred, runs from Griffith, Indiana to Sarnia, Ontario, and transports up to 190,000 barrels per day of light synthetics, heavy, and medium crude oil. The pipeline is part of the Enbridge partnerships’ Lakehead System; according to the company, 68% of Western Canadian crude exports to the U.S. in 2009 were shipped via the Lakehead System, which provides oil for refining in the Midwest and Ontario, and has increasing access to refineries in the Mid-Continent and Gulf Coast.15 An increasing amount of the crude oil shipped to and through the Midwest is being produced from tar sands (or oil sands), in Western Canada. Tar sands are a mixture of organic matter, bitumen (a viscous hydrocarbon mixture), sand and water that are either mined and processed, or extracted in situ, producing crude oil.16 Starting in 2006, production of crude oil from tar sands in Canada surpassed conventional production, and tar sands production is projected to make up an increasingly larger fraction of Canadian production in the coming decades.17 A number of concerns have been raised about the production of oil from tar sands, including regarding forest destruction and degradation, water quality impacts, human health concerns (including incidences of rare cancers) among members of indigenous communities in the Athabasca River watershed), and increased greenhouse gas emissions compared to conventional oil production.18 Parallel with increased tar sands production has been growth of pipelines in the U.S., including the Keystone XL project proposed by the company TransCanada. Two recent NWF reports have highlighted the ecological threats and harm to people that can come with these developments, including the risks from pipeline accidents. For example, from 2000- 2009, there were 2,554 significant pipeline incidences in the U.S. and 161 fatalities; Michigan ranked ninth nationally in the number of significant incidences, and three other Great Lakes states were also in the top 10.19 Pipeline corrosion (and the risk of spills) is an increasing concern with aging pipelines; Enbridge had notified the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) on July 15, 2010 concerning an alternative remediation plan to address metal loss anomalies in the pipeline identified in a June 2009 survey.20 NWF has recommended a number of policy changes (including more aggressive efforts to promote renewable energy) to lessen the environmental and other risks from our heavy reliance on petroleum (see note 19). C- Discuss the social implications of relying on more fossil fuels (obesity, respiratory health, suburban and urban sprawl, etc.).

39 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 R – Generally, when there is an abundance of a commodity such as oil, especially when the rate of resupply exceeds rates of use, prices fall as has occurred in late 2014 and early 2015. A recent report found that when prices drop, people use oil, specifically gasoline, more liberally/inefficiently. This is manifested in more miles driven and in higher overall speeds, which in turn leads to several thousand additional roadway deaths across the United States (NPR 1/06/15).

Other well-documented impacts of heavy reliance on fossil fuels include a reduction in physical activity among urban and exurban residents alike. This is a result of designing transportation systems that rely almost exclusively on car travel, which in turn creates very hazardous conditions for people who would prefer to walk or bicycle when commuting to work or performing errands.

Since the 1920s, urban areas have developed suburban and exurban low density development (commonly referred to as “sprawl”) in response to the apparent convenience of automotive travel. This has in turn increased per-unit costs for water and sewage systems; roadways; school transportation; public transit; postal and package deliveries; electric, gas, and telecommunications utility infrastructure; and a host of other costs for providing goods and services. Loss of agricultural and other open lands to this development has resulted in less energy efficient and more costly delivery of agricultural goods (NRC 1998, SRWP 2015, Toronto Star 2013).

In many large communities, respiratory health of residents is impaired by pollutants from trucks, busses and cars, even when air quality meets standards in place through 2014 (cite). C - Discuss the impact on the renewable energy industry that we had been promoting in Wisconsin. R – When oil abundance is high relative to use, and prices are low, the incentive to produce bio-fuels, bio- lubricants, bio-plastics and other products can be greatly diminished. These products can be more costly to produce than petroleum-based products, when oil is relatively abundant and prices are low. While Wisconsin’s alternative fuels industry is not as prominent as it is in states like Iowa, production/generation of products commonly produced from petroleum supports (as of date) approximately ___ jobs in our state. Additional oil at low prices would not have any measurable impact on jobs in other alternative energy industries such as photovoltaic solar, wind, or methane capture. C - One quart of water already costs more now than a gallon of gasoline and a severe spill would make clean water even more costly. R – We agree that clean water, whether for drinking, recreation, or industry, is a resources that must be guarded and protected from degradation. Drinking water inn Wisconsin is currently regarded by any as a tremendous bargain. Considering cost per thousand gallons as well as administrative and other charges, the average residential customer using 4,000 gallons per summer month in Madison pay about six tenths of a cent per gallon. Water rates tend to be a little higher in other parts of Wisconsin. C – Air quality standards are inadequate regarding the health impacts of the oil refinery in Superior. Cancer rates are reported, both anecdotally and on the basis of county public health data, to be abnormally high. Local public health officials suspect that refinery emissions are a primary cause. R – Douglas County health - Fax:(715) 395-1370. Msg to Wis Dept Health, Stats & Epidem, 02.20.15 CONDENSE: OIL AND GAS: Mont. study sees 'likely long-lasting' ecological effects from drilling Pamela King, E&E reporter Published: Friday, May 1, 2015 Though it may not be detectable when looking at a single site, the cumulative effect of energy development on loss of rangeland and cropland in the Great Plains could be significant, University of Montana researchers have found. Using satellite images, well data and information about land- and water-use patterns, the UM team estimated net primary production (NPP), or the rate at which plants in an ecosystem generate usable chemical energy. Oil and gas activity can

40 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 reduce NPP through the removal of vegetation to build oil pads, wells and other infrastructure, according to the study, which was published last week in the journal Science. "The loss of NPP is likely long-lasting and potentially permanent, as recovery or reclamation of previously drilled land has not kept pace with accelerated drilling. This is not surprising because current reclamation practices vary by land ownership and governing body, target only limited portions of the energy landscape, require substantial funding and implementation commitments and are often not initiated until the end of life of a well," the authors wrote. "Barring changes from existing trends and practices, it is likely that NPP loss and its effects (i.e., further loss of forage) will continue to parallel drilling trends and, potentially, may create unforeseen conflicts among agriculture, conservation and energy," the researchers say. By the UM researchers' calculations, the total amount of rangeland lost from oil and gas production is enough to sustain 5 million animals for one month. The amount of biomass lost from croplands is equivalent to about 10 percent of U.S. wheat exports between 2013 and 2014. "Satellite technologies now can provide annual acre-by-acre information for land managers on oil-and-gas-driven land-use changes," said Steve Running, a co-author of the paper and an ecology professor at UM. "We must have policies that ensure reclamation of this land after production has ended. Otherwise, by 2050, tens of millions of acres of land will be permanently degraded." Recent efforts by federal regulators hold some promise, according to the study. The researchers highlight wildlife protections in Alaska's petroleum reserve and an Interior Department rule to support safe, responsible fracking on public and tribal lands (E&ENews PM, Feb. 21, 2013; Greenwire, March 20). But the scope of those policies is limited to federal lands, and the majority of Great Plains energy infrastructure is installed on private property, the UM paper says. States and municipalities lack the jurisdiction to create broadly applicable rules. An 'alarmist and biased' analysis Still, advances in horizontal drilling have softened the footprint of oil and gas on the landscape, said Energy In Depth researcher Katie Brown. "Any type of energy development, whether it's a natural gas well or a wind farm, is going to have some kind of ecological footprint. But regarding shale development, Secretary of the Interior Sally Jewell put it well when she said, '[b]y using directional drilling and fracking, we have an opportunity to have a softer footprint on the land,'" Brown wrote in an email, referring an October 2013 speech by Jewell at the National Press Club. "That's because directional drilling has changed the game allowing us to produce so much more oil and gas from fewer wells. Companies are now also drilling multiple wells on a single well pad, and these are wells that can stretch miles underground, greatly reducing the surface land footprint." Because of that progress -- combined with industry's temporary nature and its mitigation efforts -- the UM study "couldn't be more alarmist and biased," said Kent Holsinger, a natural resources attorney from Denver. Holsinger has represented the Western Energy Alliance in a challenge against scientific reports used by Interior to protect greater sage grouse habitat (Greenwire, March 18). David Naugle, one of the co-authors of the UM report, has contributed to those studies. Wildlife impacts of oil extraction There is a question among conservation-oriented groups of whether shale oil development may have a negative impact on waterfowl production. In addition to the ecological importance of health waterfowl populations, waterfowl hunting contributes millions of dollars annually to the regional economies of North Dakota, Minnesota and Wisconsin. Nearly one-third of the Prairie Pothole Region overlaps with the Bakken oil field. Widely known as North America's "duck factory”, the Prairie Pothole Region covers about 276,000 square miles in parts of the Dakotas, Montana, Minnesota and Iowa and the Canadian provinces of Manitoba, Saskatchewan and Alberta. A study overseen by Ducks Unlimited is underway in the “oil patch” of northwest North Dakota and northeast Montana to gauge the impact of energy development on waterfowl productivity in the part of the Prairie Pothole Region that falls within the Bakken Formation (Dokken 2015). The study is being funded by the Prairie Pothole Joint Venture, the North Dakota Game and Fish Department, the U.S. Fish and Wildlife Service and the Central Flyway Council. Results of this three-year field investigation may not be available until some time in 2019.

41 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Response Capability, Planning and Implementation Responses to a wide range of emergencies, including spills of oil and other hazardous substances, are guided overall by the Wisconsin Emergency Response Plan. For Wisconsin DNR, responses to oil pipeline spills and leaks are more specifically guided by the Wisconsin Contingency Plan for Hazardous Substance Discharges (DNR 2013). (see: http://dnr.wi.gov/files/PDF/pubs/rr/RR585.pdf). The Wisconsin Emergency Response Plan has been developed by the Division of Emergency Management within the Wisconsin Department of Military Affairs. Within this plan is the section that covers preparedness for and responses to oil spills, under “Emergency Support Function (ESF) 10 - Oil and Hazardous Materials.” The Lead Coordinating Agency for responding to oil spills in the state is the Wisconsin Department of Natural Resources. WDNR is assisted through coordination as needed with the Division of Emergency Management, Department of Transportation, Wisconsin National Guard, Department of Agriculture, Trade & Consumer Protection, and the Department of Health Services. Facility emergency planners, local public safety emergency planners, state agency response personnel and federal agency response personnel are able to use the DNR’s Wisconsin Contingency Plan (noted above) as a resource when planning for spills, responding to a spill, or evaluating the effectiveness of a response once the response has been completed. Prompt and effective communication during a spill response is absolutely essential. To help ensure a high level of effectiveness in communications, the federal Transportation Research Board has produced RR Program State Spill Response Team The DNR manages spills through its Bureau of Remediation and Redevelopment Spill Response Team (see box). This team is comprised of a state spill coordinator, a state emergency management coordinator, a federal removals coordinator, the five regional spill coordinators and legal counsel. These staff members meet regularly to identify and resolve spill response issues and help make spill response efforts in Wisconsin as effective as possible. For management purposes, Wisconsin is divided into four emergency response regions which administer hazardous materials response teams in many counties across the state. Statewide, Wisconsin has three Type I response teams, ten Type II teams, and twelve Type III teams. These teams of all part of the Wisconsin Hazardous Materials Response System, which is coordinated by the state’s Division of Emergency Management. Responses to extensive or complex spills and other events are managed under an Incident Command System (ICS). The ICS is a management system that may involve federal oversight (through the Federal Emergency Management Agency (FEMA)) that is “designed to enable effective and efficient domestic incident management by integrating a combination of facilities, equipment, personnel, procedures, and communications operating within a common organizational structure.” The ICS is intended to coordinate activities in six major functional areas: command, operations, planning, logistics, Intelligence & Investigations, finance and administration.” The ICS is described by FEMA as a “fundamental form of management, with the purpose of enabling incident managers to identify the key concerns associated with the incident—often under urgent conditions—without sacrificing attention to any component of the command system” (FEMA 2015). Training to help develop and strengthen emergency response activities is available through FEMA. At the state and local level, there are three categories of response teams. Type III response teams handle spills or leaks of fuels (including oil and refined petroleum products) and known industrial chemicals. These teams can perform basic spill intervention and control techniques such as damming, diking, and absorption, as well as directing the technical decontamination of known chemicals. This network of county-based teams is developing the ability to respond to a fuel or chemical spill within one hour of notification. Type II response teams respond not only to fuels and known hazardous materials, but also to spills of unknown chemicals. Type II teams are prepared to arrive at the scene of a spill within 2 hours of notification. Type I response teams are trained to handle not only the fuels and known and unknown industrial chemicals that type II teams respond to, but also to known and unknown chemical weapons-of-mass-destruction (WMD) spills and other contamination events. Wisconsin so far has limited coverage by Type I response teams. 42 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 The actions of those hazardous materials response teams that are sponsored by local governments are directed by a designated Incident Commander determined under the Incident Command System, which is updated as needed. summary re: Wisconsin Contingency Plan (see Jason Lowery information below - from DNR) At the local level, s. 323, Wisconsin Statutes, requires county governments to develop a comprehensive emergency management program. Related to oil and other hazardous material spills, the county governments are responsible for establishing an emergency management organization and facility, preparing plans and procedures, issuing local emergency proclamations and requesting state assistance when appropriate. A majority (39) of Wisconsin’s 72 counties have their own hazardous materials response teams, while 17 contract with other counties that do. Two counties contract with private companies for response services, while 14 counties have no hazardous materials spill response services indicated and would have to rely upon state- coordinated responses to hazardous materials spills. (http://emergencymanagement.wi.gov/training/docs/County_Hazardous_Materials_Resp_Teams_Map.pdf). Any local government emergency response agency is authorized to request assistance for large or complex spills by contacting the state emergency management duty officer (DO) and requesting a state response team. If the nature of the spill is such that federal involvement is required, then WDNR would involve the U.S. Environmental Protection Agency and the United States Coast Guard. These agencies assist with spill response, on behalf of the agencies that are the trustees for federal water resources and wildlife, the National Oceanic and Atmospheric Administration and the US Fish and Wildlife Service. EPA maintains Regional Response Teams based within each EPA region, composed of appropriate state agencies from each state within the EPA region, as well as other federal agencies. (Wisconsin is within the six-state EPA Region V, headquartered in Chicago.) It should be noted that in the event of a spill of diluted bitumen or other heavy oil, federal assistance may be delayed or unable to address a major spill in Lake Superior. This shortfall in preparedness was highlighted in the fall of 2013, when the U.S. Coast Guard said it had “almost no capability” to respond to submerged portion of a heavy oil or diluted bitumen spill. Rear Admiral Fred Midgett, commander of the Coast Guard’s District 9, told the Detroit Free Press at the time the Coast Guard has little capability to respond to a “heavy oil” spill. A spill of heavy crude sinking into a deep coldwater environment could have far-reaching environmental and economic implications to the fish and wildlife of any Great Lakes state, potentially jeopardizing multibillion- dollar fishing and boating industries (see ttp://patch.com/michigan/dexter/pinhole-sized-pipeline-leak-raises- great-lakes-fears-0). Note: Describe applicant’s contingency plan and response teams here and note how it relates to the actions and capabilities of the above agencies and plans. Enbridge Energy has submitted an emergency response contingency plan for both its Chicago pipeline management region, and for its Superior region, to the federal Pipeline and Hazardous Materials Safety Administration of the Department of Transportation. These plans cover the entire Enbridge pipeline system within Wisconsin. The plans are reviewed to an extent deemed appropriate by PHMSA. The plans that Enbridge submitted are on file… (check also Sandpiper submittals to WDNR) From Jason Lowery, DNR Emergency Response: EPA: Ann Whelan, EPA Region V Program Analyst, 312-886-7258: Ann said that the Pipeline & Hazardous Materials Safety Adm (PHMSA) requires facility response plans for Enbridge. There are 2 for Wisconsin. One for Superior region and one for Chicago region (covers all the pipelines in WI between the 2 of them). PHMSA approves the plans but she isn’t sure how heavily they are scrutinized. The plans have to have contracts in place for equipment companies for spill response, etc. It may or may not be on the internet but it is publically available. She has one but can’t share it because it has comments for recommended improvements on it that she isn’t allowed to share. Enbridge does have a website that we may be able to get a password for. EPA regulates the facilities and PHMSA regulates the pipelines. We may have to submit FOIA request to get through PHMSA. The PHMSA contact is Eddie Murphy (Washington D.C.).

43 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 JS - EPA is currently (early 2015) reviewing Enbridge facility response plans for both the Chicago and Superior regions. Together, these plans cover spill response preparedness for all Enbridge pipelines , storage facilities and other infrastructure within the State of Wisconsin.

Get a more usable version of the following graphic, publication quality, from Jason or other source:

Comments on 2010 Enbridge pipeline spill in Michigan – these are in the NTSB report (AAR)(see link), July 2012. One highlight of the report is that it took 17 hours for Enbridge to accept the fact that there was a spill. They thought it was a bubble in pipeline. The general thought is that the preparation wasn’t adequate. Enbridge has been trying to address these problems. The incident cost them $1 billion. Being able to work with local agencies was not considered to be a strength. Their staff are spread apart though so they have to be able to work with local agencies more than they have in the past in order to best respond to these types of spill.

WEM: Frank Docimo, Hazardous Materials Training Coordinator, 608-242-3228. Referred me to Pat O’Connor, Bureau Director for Response & Recovery. Pat said that WEM doesn’t have authority over pipelines. They only have authority over facilities and pipelines are not considered facilities because they are transportation-related. Pat isn’t aware of contingency planning for Enbridge pipeline.

Michigan: Bruce Van Otteren, Michigan 517- 284-6232. I called Bruce because Michigan is where the Kalamazoo spill occurred. I spoke with Bruce on 1/30/15 and he indicated that Enbridge was fairly responsive to the spill but isn’t too sure about improvements that they’ve made in their preparedness. He did hear that they’ve made improvements though, particularly from Enbridge themselves. He is under the impression that their response is better than their spill prevention. He recommended calling Mark DuCharme at 269-567-3529 mobile 269-370-3635. Left message 1/30/15. No reply yet. Bruce indicated that I could have a difficult time getting a hold of him.

Wisconsin Contingency Plan: http://dnr.wi.gov/files/PDF/pubs/rr/RR585.pdf. This outlines the responsibilities of the various state and federal agencies involved in spill response, RP responsibilities, and the various types of plans in place to deal with large spills. It also briefly addresses some technical spill response issues (in-situ burning, dispersents, etc.).

C - The Lakehead pipeline has had at least three leaks or spills. Oil from a 1979 spill near Bemidji, MN is still trapped in the soil and groundwater, and the area is now a spill impacts research site. Oil remains in the ground a long time and poses an ecological hazard. It is only by luck that this site is relatively remote and not critical for water supply or ecological diversity. Superior hazardous materials emergency response has recently suffered a budget cut ($1 million?) (in state budget?). What will be the impact of this on our ability to respond to a spill? In the Kalamazoo spill, Enbridge line 60 discharged 1 million gallons of crude oil from a line 1/6 the capacity of Line 61. After $1 billion and 3 years work, there is still a mess. These substances are hard to clean up. Address the record and effectiveness of Enbridge pipeline company leak detection systems. They seem to be faulty, in light of 320 spills in US and 800 spills system-wide. What are the potential agricultural resources (soil, groundwater) damages in the event of a spill, how can these be cleaned up and who is responsible for the cost? Discuss Enbridge’s state of the art inspection and detection and other technological improvements. Faster responses yield smaller spills. C – Public information and awareness responsibilities seem to have been taken away from local control. Information about the Rusk County spill (year) was not available from the local county land conservationist. Instead, inquiries were rerouted to the DNR. The people overseeing responses to spills must keep our local

44 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 officials informed in real-time of current developments regarding spill responses, public health hazards, and environmental impacts. Constituents and Properties of Pipeline Products C - Disclose the chemical constituents of the diluent mixture and the chemistry of all the products that can possibly be shipped, and their health hazards. Bakken crude reportedly contains volatile solvents or explosive natural gas. This crude is not stripped of light natural gas before shipping, so it’s more flammable/volatile/explosive. It’s as flammable as unleaded gasoline. What are these substances in the products that will be shipped? R – Tar sands heavy crude oil (or “bitumen”) is a thick or highly viscous fluid, especially at low temperatures. The addition of a diluent enables the diluted fluid (“dilbit” is the term used to refer to diluted bitumen) to meet pipeline specifications in order for it to be efficiently transported. Typical diluent in this case is naphtha or natural gas condensate. The Material Safety Data Sheets (MSDS) provided in the “Keystone I Emergency Response Plan” identify a variety of substances that may be used as diluents, including synthetic crude oil, natural gas condensates, naphtha, petroleum distillates, clarified oils, and various “residues.” Technically, “diluents” are any substances that decrease the viscosity of bitumen to make it transportable. In general, diluents are lighter petroleum substances that are either naturally formed (such as natural gas condensates) or semi-refined. Diluent is not a particular chemical, but a class of petroleum substances. Basically, it tends to be the thinnest and cheapest light oil the industry can obtain in large quantities. Natural-gas condensate is a low-density mixture of hydrocarbon liquids that are present as gaseous components in the raw natural gas produced from many natural gas fields. It condenses out of the raw gas if the temperature is reduced to below the hydrocarbon dew point temperature of the raw gas. Diluents may comprise from 30% to 75% of the total contents of a pipeline at any given point. Diluent mixes can vary over time and space regarding the specific substances that comprise it, and can also vary greatly in the proportion of of each of its chemical constituents. As an example, the Shell Canada Material Data Safety Sheet (MSDS) for “Albian Heavy Synthetic Crude” lists the following constituents and ranges of proportions of each potential chemical constituent of pipeline contnets: Petroleum – crude oil 25-70% Hydrocracked Residues 30-50% Naphtha, hydrotreated Light 0-30% Natural Gas condensates 0-20% Nat Gas Condensates (C2-C20) 0-20% Residues (Petroleum) Vacuum 0-15% Distillates Hydrotreated Middle 0-12.5% Naphtha, Hydrotreated Heavy 0-12.5% Naphtha, heavy Hydrocracked 0-12% Clarified Oils, Catalytic Cracked 2-10% Naphtha, heavy straight-run 0-6% Naphtha, Light straight-run 0-6% Distillates, straight-run 0-5% Benzene 0.1-1% Xylene 0.1-0.5% Ethylbenzene 0.05-0.5%

In early January 2014, a federal agency PHMSA) alert made clear that crude oil from the Bakken formation is more prone to explosion than other types of crude oil. The warning came after tank cars carrying Bakken oil exploded in three separate railroad accidents in Alabama, North Dakota, and Quebec. (continue with other information from above)

45 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Studies regarding the potential for diluent to corrode oil pipelines from within (have not been done or conclude that… xxx) C - For example, diluent has benzene - a known causative factor for leukemia and cancer. Perform a risk & benefit analysis in light of the hazard potential of all the chemicals that people and wildlife may be exposed to. Consult the Journal of Am Med Association. Commenter (Mary Elliot) has list of health impacts references. During a refinery shut-down for clean-up, many hazardous materials. Some are odorless, clear substances that can kill or sicken people, and we need to know if we are being exposed to any of those. Some published lists of chemical content exist, but can companies can change the formulation any time. First responders need to know what substances they’re dealing with. What volatilizes into air, and what is the fate of the rest of the oil in spill? It has been shown that tar sands crude sinks in water, where it will be extremely difficult to clean up, especially in deeper water. The secrecy over what is in Enbridge’s pipelines engenders a lack of trust in industry and in government. Tar Sands oil could be processed in Superior, which can leave a huge mound of petroleum coke. In Detroit and Chicago the dry coke dust blows in the wind and constitutes a human health hazard. Is this planned for Superior? Is the chemical nature of tar sands crude such that it may promote a spill or pipeline rupture because it is more corrosive than conventional crude oil? R – Bitumen has been characterized as “acidic” by several accounts. It is a mixture of C - There have been no true corrosion or abrasions tests of tar sands crude. Show the results of variable pressure stress, heat exposure and corrosion tests. R – Bitumen, or “tar sands crude” reportedly contains a high concentration of abrasive sand that remains after the initial separation of the petroleum component from the soil and other material from which it is extracted. The heat effect of oil flowing through a pipeline can result from a combination of two factors. The bitumen or petroleum in a pipeline may be heated with another fossil fuel in order to promote flowing through the pipe, or the friction of the moving oil within the pipe can generate some amount of heat. Bitumen (from “tar sands,” including a diluting fluid such as benzene of something similar) reportedly creates much more friction and heat than conventional crude oil, due to the presence of sand left over from the extraction process. Federal regulators examining the May, 2015 oil spill off the California coast said the pipeline in question showed signs of extensive corrosion. A pipeline system operated by Plains All American, which has headquarters in Houston, leaked as much as 2,500 barrels of oil in Santa Barbara County in mid-May. About 500 barrels may have reached the waters off the coast of Refugio State Beach in a release the Environmental Protection Agency said was the worst spill in California in the last 25 years. The federal Pipeline and Hazardous Materials Safety Administration released their preliminary findings of the integrity of the pipeline system. PHMSA said it found "extensive" corrosion, with walls degraded by as much as 74 percent of their original thickness in some locations. "The rupture characteristics at the failure site indicate a longitudinally oriented opening approximately 6 inches in length and located in the bottom quadrant of the pipe," PHMSA said its findings. Plains said it had conducted a system inspection two weeks before the May 19 spill, though results weren't returned until after the incident.

Environmental Health and Economic Health - Risk and Benefit Analysis Address the issue of who gains from transporting oil, and who bares the risk. Describe who is responsible for public safety in the operation of petroleum pipelines. Is it FIMSA? If so, note that that agency is understaffed and poorly organized. There seems to be no real energy gain for Wisconsin and few other benefits to Wisconsin. What are the benefits? Canada gains nearly all the economic benefits, as much of the tar sands crude is exported internationally, out of North America.

46 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Spill cleanup is generally very costly. Describe in detail what financial assurance mechanisms exist to ensure that Enbridge will pay all associated costs of spills and other property and resource damage, so that these costs are not borne by property owners and taxpayers. How will any spill cleanup fund be managed and by whom? Spill costs fall on landowners, and taxpayers, and are also borne by wildlife. Examine what these cost are and disclose why they are not fully paid by the pipeline company. Spill costs mandate that more money be used in construction and spill prevention (up-front investment), rather than spending more money and suffering resource damage costs after a spill or leak occurs. Regarding any “safe and reliable” claim – pipeline operation outcomes are not as good as the state safety goals. There have been 800 failures since 1999 with Enbridge pipelines. 45,000T soil had to be removed after a leak near Marshfield. If these petroleum products are unduly explosive and corrosive, then stabilize them before shipping them, regardless of the transportation method. Include post-construction environmental data and share the risk data. The practice of “blanketing” products delivered by pipeline poses safety and response concerns. The company is changing contents from one petroleum product type to another, separated by a “blanket.” How can responders know what they are dealing with? Report the results of inspection “pig” X-ray runs on a public data site. Stop using “Canadian Crude” nomenclature for tar sands crude. This is a vastly different product from the conventional crude collected simply by pumping, which the U.S. also imports from Canada. With Line 61 DNR did nothing after construction. We need to address post-construction operation hazards. How much of Canada’s tar sands crude oil will be exported from the US? How does this impact future North American energy independence and security? How does this impact the economic competitiveness of the U.S. when this oil can be used to transport people to jobs in China that used to be performed here by Americans? For Bakken shale oil, look at historical data re: human error causing most spills (puncture, operator error). Statistically, over a 30 year period this pipeline would almost certainly rupture or leak. Also include a worst-case scenario, using the largest amount in the worst location (ecologically and also sociologically). This can help make a valid cost-benefit analysis. Don’t just include tax revenue and job income. With the Superior tank farm, Enbridge and Canada seem merely to use Wisconsin as part of an energy freeway to export their oil. The North Dakota shale oil development rush creates a burden on and pipeline capacity that has now spilled over into a rail capacity shortage. This causes delays in shipping other vital commodities, especially food. There has been a 60% drop in pipeline spills since 1994 (PHMSA). Lines 3 and 67 are related – the elbow in the line’s path at the [Canadian?] border was made to skirt the intent of law. Abandoned pipelines should be removed carefully to eliminate the hazard of sludge seepage or leakage once the pipe rusts through. “Leave no Trace” should be the practice. EIS needs to address this abandonment risk, both leaving a pipe in place, and removing abandoned pipelines. The proposed pipeline is too close to Lake Superior. Many people make their living based on a clean Lake Superior. How would people be compensated for loss of livelihood? The Exxon Valdez disaster and Louisiana Gulf leaks and spills took far too long to resolve, both financially and ecologically. Energy Independence and Security Many life activities currently depend on fossil energy. A strong nation requires “energy independence” [note though that recent-past strength was result of lots of imported oil]. Energy independence is best achieved with pipelines, which can be installed and operated with minimal intrusion on neighboring properties. How much of Canada’s tar sands crude oil will be exported from the US? Where’s it going? How much will be used in the U.S? How does this impact future North American energy independence and security?

47 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Oil companies and others in the U.S. are attempting to end the ban on exporting oil, because high fracking volumes have created an over-supply and driven domestic prices down, leaving oil companies desiring to sell to Asian markets that will pay a higher price. Industry-wide claims regarding ensuring energy security for the U.S. seem untrue in this light. Return on energy investment on tar sands is much smaller than with conventional crude. Discuss the impact on the U.S. in the future of this trend to ever more expensive oil extraction methods vs importing more conventional oil from other nations (including Canada). Recovery efficiency (ratio of energy extracted to energy sources expended) has gone from 80:1 to now 3:1. This is a sign we need to be switching to other transportation fuels. (U.S. refined gasoline exports hit an all-time high in 2012, due to a 6% decrease in domestic automotive fuel use and an expansion of refining capacity, since 2006: http://www.eia.gov/oog/info/twip/twiparch/120321/twipprint.html) Landowner Relations C - Landowners are treated poorly by Enbridge and its contractors, in some instances. Many legal and cost problems revert to the landowner, are not addressed by easements. R – DNR has no database regarding complaints from landowners but does have records of complaints and requests from landowners that DNR intervene in disputes regarding removal of mature trees, proximity of pipeline location to homes, removal of unearthed rocks and stones from farm fields, excessive smoke caused by burning green trees removed during construction, burning creosote-impregnated timbers, and other issues. C - Anecdote - Original pipe placed across one farm was OK, but Enbridge set the next one some years later too shallow, so that it interfered with agricultural operations. “You can get a lawyer” they told farmer when he asked to have the new line set as deeply as the first. C - Enbridge won’t sit and meet with people impacted by the expanded Superior tank farm. [Weren’t they holding a meeting there that same night as the DNR hearing?] C - One landowner claims for Enbridge has trespassed on his land for 12 years with a pipeline. The company has not been truthful to state regulators and landowners. Enbridge had this landowner’s son arrested for trespass on his own land, and the charges were later dropped. DNR (and other?) permitting rules are not effective. Eight lines cross through one property with 5 of these off the valid easement. Now Enbridge is trying to reroute a new line around his land, on [Douglas?] county property. C - Abandoned pipeline needs to be removed, not allowed to “rot.” Lots of sludge is left behind. Right-of-Way (ROW) restoration & maintenance is supposed to be completed, to 70% [of soil? original vegetation?], but DNR does not enforce this. Nothing but grass grows has grown on one landowner’s ROW land for the past 12 years. His land that was once covered in trees and wetlands is now open grasslands. R – The DNR permit condition regarding Right of Way (ROW) restoration and maintenance requires only certain degree of restoration of public-interest resources (primarily streams, lakes and wetlands). The restoration and maintenance of privately owned upland sites is a matter between the pipeline or utility company and the landowner, and DNR has no authority to impose or enforce conditions regarding these sites. Typically, pipeline companies and utilities want to be able to quickly and easily access their infrastructure corridors in the event of a leak, spill, line break or pole failure. This emergency access is generally best assured by keeping the corridor in grass and shrub cover, which stabilizes soil while affording unimpeded emergency access. C - DNR should require Enbridge to show signed easement contracts for the entire route before any permit can be granted. Not all landowners have has signed easement agreements, so Enbridge is suing them via Eminent Domain, but without demonstrating any public need for the pipeline. The EIS should forbid this. Permit Decision C - Ignore added shipping cost in selecting an approvable alternative or permit conditions for a permit decision. R – DNR permitting staff do not have authority to factor the cost of alternatives into a pipeline permit decision. The factors DNR may use in its permit decisions involve an evaluation of potential impacts to wetland and aquatic resources, and the actions that an applicant must take in order to control negative impacts so that they

48 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 meet applicable water quality, wetlands protection, and endangered resources standards that are in state statutes and administrative rules.

References Consulted Adler, Ben. 2015. Why more pipelines won’t solve the problem of oil train explosions. http://grist.org/politics/why- more-pipelines-wont-solve-the-problem-of-oil-train-explosions/? utm_campaign=horizon_daily_feed&utm_medium=email&utm_source=newsletter. Agency for Toxic Substances and Disease Registry (ATSDR). 2014. Toxic substances portal: n-Hexane. http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=392&tid=68. Accessed 23 February, 2015. Agency for Toxic Substances and Disease Registry (ATSDR). 2014. Toxic substances portal: Toluene. http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=160&tid=29. Accessed 23 February, 2015. Agency for Toxic Substances and Disease Registry (ATSDR). 2014. Toxic substances portal: Hydrogen sulfide. http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=160&tid=29. Accessed 23 February, 2015. Alred, Brady W., WK Smith, et al. 2015. Ecosystem services lost to oil and gas in North America. Science 24 April 2015: Vol. 348 no. 6233 pp. 401-402. DOI: 10.1126/science.aaa4785. http://www.sciencemag.org/content/348/6233/401.full Associated Press. 2015. Railway now says 21 cars derailed from oil train in Illinois. March 5, 2015, updated March 6, 2015. http://www.channel3000.com/news/railway-now-says-21-cars-derailed-from-oil-train-in- illinois/31638518. Accessed March 6, 2015. Bailey and Droitch. 2015. Natural Resources Defense Council. http://www.nrdc.org/energy/tar-sands-health- effects.asp Barsamian, Melissa. FishVis forecasts climate change effects on fish. Superior Telegram. http://www.superiortelegram.com/news/douglas-county/3645490-fishvis-forecasts-climate-change-effects-fish. Posted on Jan 2, 2015 at 8:29 a.m. CBC News 2014. CN derailment near Plaster Rock involved mechanical failure. http://www.cbc.ca/news/canada/new- brunswick/cn-derailment-near-plaster-rock-involved-mechanical-failure-1.2488358. January 8, 2014. Accessed Feb. 19, 2015. CBC News. 2015. Gogama oil spill raises concerns about environmental damage - cleanup continues at the site of a CN train derailment about 30 km northwest of Gogama, Ont. Last Updated: Feb 18, 2015 11:57 AM ET. http://www.cbc.ca/news/canada/sudbury/gogama-oil-spill-raises-concerns-about-environmental-damage- 1.2961404. Accessed Feb. 18, 2015. Center for Biological Diversity (CFBD). 2015. Legal Petition Urges Gov. Brown to Impose Emergency Fracking Moratorium After Oil Waste Illegally Dumped Into California Aquifers. 26 Feb. 2015. http://www.biologicaldiversity.org/news/press_releases/2015/fracking-02-26-2015.html. Accessed Feb. 27, 2015. Davis, Carolyn. 2013. Marked Production Growth Ahead for Deepwater GOM, Says Wood Mackenzie. http://www.naturalgasintel.com/articles/100406-marked-production-growth-ahead-for-deepwater-gom-says- wood-mackenzie. November 13, 2014. Dokken, Brad. 2015. Ducks in the Bakken: DU research project aims to shed light on impact of oil and gas development on duck production and density. The Dickinson Press. May 23, 2015. http://www.thedickinsonpress.com/news/north-dakota/3751865-ducks-bakken-du-research-project-aims-shed- light-impact-oil-and-gas. Ellison, G. 2014. http://www.mlive.com/news/grand- rapids/index.ssf/2014/11/2010_oil_spill_cost_enbridge_1.html

49 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Enbridge Energy. 2009. Enbridge 2009 Corporate Social Responsibility Report. http://www.enbridge.com/csr2009/downloads/Enbridge-2009-CSR-Report.pdf Enbridge Energy. 2014. 2013 operational reliability report. http://csr.enbridge.com/~/media/www/Site %20Documents/About%20Enbridge/2013%20Operational%20Reliability%20Review.pdf?la=en E-News Park Forest (ENPF) 2015. Legal Petition Urges Gov. Brown to Impose Emergency Fracking Moratorium After Oil Waste Illegally Dumped Into California Aquifers. 26 Feb. 2015. http://www.enewspf.com/latest-news/science/science-a-environmental/59484-legal-petition-urges-gov-brown- to-impose-emergency-fracking-moratorium-after-oil-waste-illegally-dumped-into-california-aquifers.html. Accessed Feb. 27, 2015. Environment News Service (ENS). 2015. Fiery Oil Train Crash Lights Up Frozen Ontario Woods. http://ens- newswire.com/2015/02/16/fiery-oil-train-crash-lights-up-frozen-ontario-woods/. February 16, 2015. Accessed Feb. 19, 2015. Epstein E., Spencer L. and D. Feldkirchner. 2002. A data compilation and assessment of coastal wetlands of Wisconsin’s Great Lakes – final report. WDNR Natural Heritage Inventory Program, Bureaus of Endangered Resources, Madison. PUBL-ER-803 2002. http://dnr.wi.gov/files/PDF/pubs/er/ER0803.pdf. Epstein E.J., E.J. Judziewicz and W.A. Smith. 1997. Priority wetland sites of Wisconsin’s Lake Superior Basin. http://dnr.wi.gov, Keyword: “Priority wetland sites of Wisconsin’s Lake Superior Basin.” Excerpted from: Wisconsin’s Lake Superior coastal wetlands evaluation including other selected natural features of the Lake Superior Basin. A Report to the Great Lakes National Program Office - U.S. Environmental Protection Agency. PUB ER-095 99 http://dnr.wi.gov/topic/Wetlands/cw/pdfs/superior/superior_text.pdf. Federal Emergency Management Agency (FEMA). 2015. Incident Command System Resources. https://www.fema.gov/national-incident-management-system/incident-command-system-resources Goldenberg, Suzanne. 2015. Canada reneges on emissions targets as tar sands production takes its toll - a new pledge to cut greenhouse gases by 30% from 2005 levels by 2030 is less ambitious than previous goal and lags far behind US and EU targets. The Guardian. http://www.theguardian.com/world/2015/may/15/canada- reneges-emissions-targets-tar-sands-production. Accessed 18 May 2015. Deborah Gordon, Adam Brandt, Joule Bergerson, Jonathan Koomey 2015. Know Your Oil: Creating a Global Oil-Climate Index. March 11, 2015 http://carnegieendowment.org/2015/03/11/know-your-oil-creating- global-oil-climate-index/i3oy#. Dokken, Brad. 2015. Ducks in the Bakken: DU research project aims to shed light on impact of oil and gas development on duck production and density. The Dickinson Press. May 23, 2015. http://www.thedickinsonpress.com/news/north-dakota/3751865-ducks-bakken-du-research-project-aims-shed- light-impact-oil-and-gas. Graeber, Daniel J. 2015. PHMSA: California oil pipeline corroded - It would be hazardous to restart pipeline system, federal audit finds. UPI. http://www.upi.com/Business_News/Energy-Resources/2015/06/04/PHMSA- California-oil-pipeline-corroded/2221433415086/ . June 4, 2015. Accessed 8 Jun 2015. Hubbuc, Chris. 2015. Oil train traffic down on BNSF lines in Minnesota, Wisconsin. June 30, 2015. http://marcellus.com/news/id/125327/oil-train-traffic-down-on-bnsf-lines-in-minnesota-wisconsin. Accessed 30 Jun 2015. Hulac, Benjamin. 2015. Alberta puts pressure on oil sands with plan to double carbon fee. E&E Publishing. June 26, 2015. http://www.eenews.net/stories/1060020959. Accessed 26 Jun 2015.

Irwin, Dawid. Petroleum's Coke Problem Plagues Chicago. http://www.planetizen.com/node/66602. Accessed 5 Jan 2015. Jacobs Consultancy, Inc. (JCI). 2005. Petcoke quarterly. http://www.airproducts.com/~/media/Files/PDF/industries/petroleum-refining-refueling-oil-fired-boilers- petroleum-coke.pdf

50 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Kelly, Sharon. 2014. US shale oil drillers flaring and venting billions of dollars in natural gas. Ecologist, 20th September 2014. http://www.theecologist.org/News/news_analysis/2562341/us_shale_oil_drillers_flaring_and_venting_billions_ of_dollars_in_natural_gas.html. Accessed 30 Jan 2015. Lakeland Public Television. 2015. Lakeland Currents 705 – Moving Canadian Tar Sands and Bakken Crude Oil to Market: The Minnesota Connection. Broadcast January 8, 2015. http://www.lptv.org/lakeland-currents- moving-canadian-tar-sands-and-bakken-crude-oil-to-market-the-minnesota-connection/ Lehmann, Evan. 2015. Researchers say the social cost of carbon will be 6 times the Obama administration's estimate. Energy and Environment News - ClimateWire: Tuesday, January 13, 2015. http://www.eenews.net/stories/1060011557/print. Lewis, Jeff. 2015. Canadian crude shipments from U.S. Gulf hitting global markets. The Globe and Mail. http://www.theglobeandmail.com/report-on-business/industry-news/energy-and-resources/canadian-crude- shipments-from-us-gulf-hitting-global-markets/article24037483. Published Monday, Apr. 20 2015. Accessed 22 April 2015. Magill, B. 2015. Scientists Call for Halt to Canadian Oil Sands Expansion. Climate Central. June 10th, 2015. http://www.climatecentral.org/news/scientists-oil-sands-expansion-19096. Access 11 Jun 2015. Mallakpour, Iman and Gabrielle Villarini. 2015. The changing nature of flooding across the central United States. Nature Climate Change. February 9, 2015. doi:10.1038/nclimate2516. http://www.nature.com/nclimate/journal/vaop/ncurrent/full/nclimate2516.html. Accessed 11 Feb. 2015. Maritime Executive. 2015. Update: Singapore: Oil Tanker and Bulk Carrier Collide. January 2, 2015. http://www.maritime-executive.com/article/singapore-oil-tanker-and-bulk-carrier-collide McDiarmid, Jessica. 2014. Brockville train derailment ‘could have been a lot worse’ - CN train skipped the tracks outside town, with empty tankers that carried only residue of jet fuel. Toronto Star. July 10 2014. http://beniciaindependent.com/topics/derailment/page/41/ National Highway Traffic Safety Administration (NHTSA). 2015. Performance fact sheet- toluene. http://www.nhtsa.gov/People/injury/research/job185drugs/toluene.htm National Research Council – Transportation Research Board (NRC). 1998. The costs of sprawl – revisited. http://www.trb.org/Main/Public/Blurbs/153808.aspx. National Transportation Safety Board (NTSB). 2010. Enbridge Incorporated Hazardous Liquid Pipeline Rupture and Release, Marshall, Michigan. July 25, 2010. http://www.ntsb.gov/investigations/AccidentReports/Reports/PAR1201.pdf. Accessed Feb. 13, 2015. National Wildlife Federation. 2010. The Enbridge oil spill. http://www.nwf.org/~/media/PDFs/Regional/Great- Lakes/GreatLakes_MI_Factsheet_KalamazooOilSpill_080910.pdf. August 2010. Accessed January 29, 2015. Polaris Institute. https://d3n8a8pro7vhmx.cloudfront.net/polarisinstitute/pages/29/attachments/original/1410802206/Updated_En bridge_Profile_March_2012.pdf?1410802206. Sacramento River Watershed Program (SWRP). 2015. http://www.sacriver.org/aboutwatershed/rural/background%20primer%20rural%20residential %20development/costs-sprawl. Scheyder, Earnest. 2015. Nearly three million gallons of salt water leak into North Dakota creek. http://news.yahoo.com/nearly-three-million-gallons-saltwater-leak-north-dakota-162500618--finance.html. January 22, 2015. Schor, Elana and A. Restuccia. 2015. Pipelines blow up and people die. Politico. http://www.politico.com/story/2015/04/the-little-pipeline-agency-that-couldnt-117147.html#ixzz3ZSsaNcut. Updated 4/22/15. Accessed 7 May 2105.

51 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 Shaffer, David. 2015. Minnesota PUC approves Enbridge's Sandpiper pipeline but didn't settle its route. Minneapolis Star Tribune. June 6, 2015. http://www.startribune.com/minnesota-puc-approves-new-enbridge- pipeline-but-didn-t-settle-its-route/306307461/ Stockman, Lorne. 2013. Petroleum coke: the coal hiding in the tar sands. Oil Change International. Jan. 13, 2013. http://priceofoil.org/2013/01/17/petroleum-coke-the-coal-hiding-in-the-tar-sands/ The Guardian. 2015. Huge fire in West Virginia after oil train derails, sending tanker into river. http://www.theguardian.com/us-news/2015/feb/16/train-crude-oil-derails-in-west-virginia. February 16, 2015. Toronto Star. 2013. Hidden costs of sprawl will cripple cities, report says. http://www.thestar.com/news/gta/2013/10/28/hidden_costs_of_sprawl_will_cripple_cities_report_says.html. US EIA. 2015. Petroleum and other Liquids – US imports by country of origin (through November 2014). http://www.eia.gov/dnav/pet/pet_move_impcus_a2_nus_ep00_im0_mbbl_m.htm. January 29, 2015. Accessed February 10, 2015. US EIA. 2014. Petroleum and other Liquids – Exports (through September 2014). http://www.eia.gov/dnav/pet/pet_move_exp_dc_nus-z00_mbblpd_m.htm. US EPA. 2014. Technical support document: technical update of the social cost of carbon for regulatory impact analysis under Executive Order 12866 – interagency working group on social cost of carbon, United States Government. http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pd. Accessed 2 Feb. 2015. US EPA. 2013. The social cost of carbon. http://www.epa.gov/climatechange/EPAactivities/economics/scc.html, Accessed 10 Feb. 2015. US EPA. 2012. Great Lakes fact sheet #3. http://www.epa.gov/greatlakes/atlas/gl-fact3.html#b. Last updated 06/25/2012 Accessed 18 February, 2015. US Fish and Wildlife Service (USFWS). 2015. Natural Resource Damage Assessment and Restoration - 2010 Enbridge Oil Spill in Michigan: Enbridge Must Restore Environment Injured by 2010 Kalamazoo River Oil Spill. June 8, 2015. http://www.fws.gov/midwest/es/ec/nrda/MichiganEnbridge/. Accessed 9 Jun 2015. WDBJ7. 2015. Train carrying crude oil derails in Lynchburg. http://www.wdbj7.com/news/local/reports-of- train-derailment-in-lynchburg/25738530. April 30, 2014. Accessed Feb. 19, 2015. Wisconsin Contingency Plan for Hazardous Substance Discharges. 2013. Wisconsin Department of Natural Resources, Bureau for Remediation and Redevelopment, Madison, WI. June 2013. Publication # RR-585. http://dnr.wi.gov/files/PDF/pubs/rr/RR585.pdf Wisconsin Department of Health Services. 2014. Climate and Health. https://www.dhs.wisconsin.gov/climate/index.htm. Revised: November 21, 2014. Accessed December 16, 2014. Wisconsin Department of Natural Resources and Wisconsin Public Service Commission. 2008. Wisconsin’s Strategy for Reducing Global Warming. Task Force on Global Warming – Wisconsin Department of Natural Resources and Wisconsin Public Service Commission. July 2008. http://legis.wisconsin.gov/assembly/asm23/news/Hot%20Air/GWTF%20Final_Report.pdf Appendices Appendix 1 – Wisconsin DNR Climate Adaptation Talking Points Wisconsin DNR [Anonymous Administrators], December 2014 1. As you are aware, the subject of global climate change, the causes thereof, and the measures needed to mitigate it are matters of some dispute in the global stage. The Department [i.e. unidentified political appointees who developed these talking points] believes that until this dispute is resolved, and until a federal climate change policy supported by Congress is promulgated, it is premature for individual states to take unilateral action [presumably even when that action would provide an ecosystem or economic benefit regardless of what other states or the federal government does].

52 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015 2. As a result, and unlike the previous administration [i.e. Governor Doyle] the Department does not work on any mitigation efforts to reduce carbon emissions, save those mandated by the federal government through EPA rule or requirement. 3. What is clearer to the Department is that Wisconsin has entered into a period of time of temperature and precipitation-related weather events that are significant both in their extent and frequency as compared to long- term records. While not focused on causal factors, we do believe it is responsible for the agency to undertake adaption [sic] planning and resource management actions in response. 4. While using predictive modeling generated by the University of Wisconsin as a starting framework, the Department bases its adaptive management recommendations on a data base of 50 years of historic weather data from Wisconsin that we believe more accurately shows deviations of events from norms from that data base. Additional contemporary data is added each year to the data base to ensure we are using the most recent and accurate Wisconsin-based information and trends. 5. Climate adaption topical areas that the Department is currently engaged in include: silvicultural practices, flooding frequency and magnitude, drought frequency and duration, stream flows and temperature, fish and wildlife species viability and forestry biomass. 6. All of the above topical areas have direct and indirect impacts on Wisconsin’s citizenry, environment, and economy and as such, the Department has an obligation to respond to its business and customer needs to plan for an adapt to these events.

Appendix 2 – U.S. Crude Oil Production: 1991 - 2015

53 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

Appendix 2 - U.S. Crude Oil Production -- 1991 - 2015 Source: https://www.aar.org/todays-railroads/what-we-haul/crude-oil-by-rail

54 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

Appendix 3 - Greenhouse Gas Emissions by Crude Oil Source - From: http://carnegieendowment.org/2015/03/11/know-your-oil-creating- global-oil-climate-index/i3oy#

55 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

https://www.aar.org/todays-railroads/what-we-haul/crude-oil-by-rail

56 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

From: http://www.politico.com/story/2015/04/the-little-pipeline-agency-that-couldnt-117147.html

57 Enbridge Sandpiper EIS Scoping White Paper July 3, 2015

From: http://www.politico.com/story/2015/04/the-little-pipeline-agency-that-couldnt-117147.html

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