August 25, 2015
Public Utilities Commission
121 7th Place East, ste 350
Saint Paul, MN 55101-2147
MN Department of Commerce
85 7th Place East ste 500
Saint Paul, MN 55101
Re: Line #3 Replacement Project --- Docket PL-9/CN-14-916 & PL-9/PPL-15137
Dear Public Utilities Commission and Department of Commerce,
I urge the need and routing permit for the Line #3 Replacement Project within the route corridor requested be granted without delay.
There is a need to replace aging Line #3 with a new modem pipeline. Failing to replace or delaying replacement endangers public safety by eventually forcing more crude oil onto the rails. Operating an aging pipeline increases the potential for environmental damage.
My testimony and letter on the Sand Piper Pipeline Project of January 9, 2015 concerning public safety remains valid. There is a pressing public safety need to decrease the amount of crude oil transported through Minnesota by rail and truck. GA0-14-667 Oil and Gas Transportation report of August 21, 2014 states the following with respect the public safety aspects of transporting crude oil by pipeline versus other less safe modes of transportation:
"Inherent sefety risks: Transporting oil and gas by any means through pipelines, rail, truck, or barge-poses inherent sefety risks. However, in January 2013, we found that pipelines are relativejy safe when compared with other modes, such as rail and truck, for transporting hazardous goods because pipelines are mostly underground.
For example, we found that large trucks and rail cars transporting hazardous materials, including crude oil and natural gas liquids, resulted in far more fatalities and incidents than pipelines. "
I urge the Public Utilities Commission and the Department of Commerce to work through the permitting process without delay and give public safety the highest priority.
The technology exists to build and safely operate pipelines through what some would label ''ecologically sensitive" areas. However, as I stated in January of this year, we do not have the technology to recover lives lost due to accidents that will surely result if the Commission and Commerce place manageable environmental concerns ahead of public safety.
Secondary to the public safety issue of not replacing Line #3 in an expeditious manner is the risk to the environment of operating an aging pipeline that for many miles runs very close to the Mississippi River between Bemidji and Grand Rapids, Minnesota. The new proposed route for the Clearbrook to Superior segment moves the majority of Line #3 many miles away from the Mississippi River. This route reduces the risk of an almost immediate discharge of crude oil directly into the main body of the river, should a leak occur.
An additional important element of this project is the long term economic benefit this project would bring to the area. An example is the proposed pumping station near the City of Palisade, MN. That would bring both construction related and permanent jobs to the area. The citizens of Aitkin and Crow Wing County would benefit from increased property tax revenue based on following the route proposed in this application. That would have an especially large and positive impact on the property tax payers within the school districts and townships of Aitkin County.
The additional of new property tax revenue for Aitkin County is estimated to be in the several millions of dollars annually should the proposed route for the Sandpiper and the Line #3 replacement project be followed.
I would also ask both the Commission and Commerce to put the discussion of alternative routes into proper perspective. Some citizen groups, the Minnesota Department of Natural Resources and the Minnesota Pollution Control Agency suggest using completely different routes from that included in the application before you.
Regardless of where pipelines are routed it will be in someone's watershed and backyard. Pipelines transiting Minnesota will almost always cross some portion of the Mississippi Watershed. I would suggest that the focus should be on ensuring that the best engineering and highest construction standards are implemented with respect to dealing with ecologically sensitive areas, rather than wholesale shifting of the proposed route.
Attempting to significantly shift from the route contained in the application calls into question the efficacy of the permitting process and the role of both the Public Utilities Commission and Department of Commerce, as well as the MN DNR and MPCA as supporting state agencies. Attempting to determine whose backyard is more ecologically sensitive among the citizens of Minnesota quickly takes us down a very subjective and unnecessarily emotionally charged path. Everyone can rightfully claim their backyard is more sensitive.
I ask the Commission and Commerce to place public safety ahead of what are clearly legitimate, but very manageable environmental concerns. It is important to recognize that unwarranted delay in reaching a decision on the matter before you likely means more crude oil on the rails with an increased safety risk to both rural and metro citizens in Minnesota. We are all interested in ensuring both public safety and protection of our wonderful environment here in Minnesota. Thank you for considering my comments.
Dale K Lueck
Commissioner Tom Landwehr, MN DNR, Commissioner John Stine, MPCA