A submission to the National Energy Board.

Submission A53195: Commenting on Enbridge Pipelines Inc. Line 9B Reversal and Line 9 Capacity Expansion Project.

According to the National Energy Board’s stated purpose, it is to promote safety and security, environmental protection and efficient energy infrastructure and markets in the Canadian public interest… And on this basis alone, the Line 9 Capacity Expansion Project cannot be allowed to run through Canada’s largest city.

It is not a question as to whether Enbridge Pipelines is going to be extra vigilant, more thorough in testing and inspecting, or wants to call bitumen slurry by some other name, a spill can be a disaster in the lives of people. Ask the people who live along the Kalamazoo River and its tributaries in Michigan. What has three years of trying to clean up the mess of that bitumen slurry spill meant to them?

Enbridge certainly does not want nor expect a spill in Toronto. One of the reasons most people have not been aware of this pipeline through the city is that it runs mostly through a high-voltage power line right of way and there was very little awareness of the installation two decades ago.

With the very serious ecological concerns for carrying bitumen instead of crude oil, there is little hope of this application not becoming much broader knowledge.

Bitumen is not crude oil, neither light nor heavy. In order to flow, bitumen must be diluted. Possible diluents include synthetic crude and naphtha. Heating can also improve the flow and this is done by adding a natural gas heater at every pumping station. Also, increasing the pressure will speed flow, putting additional strain on an old pipeline.

Mind you, the application makes little reference to the shipping of bitumen. One gets the impression that this is a minor item in the general scheme—if it were not for the forecasts of the amount of oils sands bitumen the various companies in Alberta are forecasting that they intend to ship.

When the writer offered to develop some scenarios for the National Energy Board, it was to intervene as a citizen who had knowledge of the area in which the line travels through Toronto. We offered to research scenarios of what a range of spills could mean in a dense urban environment. Research of this type draws heavily on the pipeline company, area emergency first-responders, public services (including transit) and interviews with managers of office buildings and condominiums in the area. Commercial preparation of scenarios of this type can take from six to 12 month and can cost hundreds of thousands. As a commenter, it is not possible to provide that level of work nor can we expect the cooperation of Enbridge for such a task.

What we have therefore decided to do is provide a selection of commentaries we have written for our blog, The blog, Babel-on-the-Bay ( babelonthebay.com ) is a political commentary. Two of the comments touch on the type of studies we had in mind and the others are various commentaries that reference the Line 9B Reversal and Line 9 Capacity Expansion Project.

(To access postings click on the link.)

Commentary #1

BABEL-ON-THE-BAY July 14, 2012

http://babelonthebay.com/2012/07/14/calamity-kalamazoo-cancel-b-c-pipeline/

Commentary #2

BABEL-ON-THE-BAY February 12, 2013

http://babelonthebay.com/2013/02/12/tar-sands-politicians-pipelines-greed/

Commentary #3

BABEL-ON-THE-BAY March 16, 2013

http://babelonthebay.com/2013/05/19/wait-for-it-the-royal-northern-gateway-pipeline/

Commentary #4

BABEL-ON-THE-BAY June 5, 2013