Planning for Enbridge’s Line 3 Replacement Project started years ago. Throughout the process to look at the route, review the permits and other issues, there have been many voices involved in the conversation. With so much information being shared and gathered about Line 3, it’s important to help everyone stay focused on the facts, address any misconceptions and make sure that information about Line 3 is grounded in truth.

Minnesotans for Line 3 has identified some common questions about the Line 3 project as well as information, facts and other background that are important to keep in mind as the process moves forward. The most important fact is how important the Line 3 replacement is for all Minnesotans, why we need it, and how thorough and rigorous the planning process has been.

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Who made the decision to replace Line 3, and when did it happen?

Who made the decision to replace Line 3, and when did it happen?

Several different parties have recommended replacing Line 3. This includes the United States Department of Justice and Environmental Protection Agency under the Obama administration, the Minnesota Public Utilities Commission, an administrative law judge, as well as Enbridge.

Safe and reliable operations have always been the foundation of Enbridge’s business, and maintaining pipeline integrity is essential to continued safe and reliable operations. As part of Enbridge’s  maintenance program they gathered, and continue to gather extensive integrity data on Line 3. Since 2008, Enbridge has safely operated and maintained Line 3 by implementing voluntary pressure restrictions reducing the average annual capacity of deliveries from 760,000 barrels per day (bpd) to 390,000 bpd. This means the pipeline is only able to carry about half as much oil as it was originally designed to.

As a result of the integrity maintenance program, Enbridge concluded that replacement is the best alternative to the required ongoing and increasing maintenance activities for this important part of the region’s energy. Replacing the line that was built in the late 1960s with a new, modern pipe will increase safety and capacity.

In April of 2015, Enbridge submitted their application for replacement of Line 3 to the Minnesota Public Utilities Commission as part of its integrity and maintenance driven program. Since that time the project has undergone the most extensive Environmental Impact Study in Minnesota history related to pipeline projects. State agency staff spent 16 months drafting a 5,000-page analysis developed in accordance with the law. Over 65 public meetings were held, and thousands of public comments were received into the public record. In 2017, an administrative law judge concluded that from an environmental perspective, replacing Line 3 is superior to maintaining the existing line.

In 2016, Enbridge entered into a settlement agreement with the U.S. Department of Justice and Environmental Protection Agency, both led by Obama appointees at the time. As part of the agreement, the U.S. Government required Enbridge to replace its 1960s era Line 3 pipeline.

On June 28, 2018, the Minnesota Public Utilities Commission unanimously approved the Certificate of Need and approved the Route Permit in a 3-2 decision.

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What steps have been taken to approve the Line 3 project?

What steps have been taken to approve the Line 3 project?

The Line 3 Replacement Project continues to go through an extensive review process that has already taken more than four years. The review process was created to make sure the project is safe, necessary, and beneficial for Minnesota. This process has included:

  • Support from both the Obama and Trump administrations;
  • 65 public meetings about the project;
  • Support by two Administrative Law Judges;
  • Unanimous approval by the Minnesota Public Utilities commission;
  • Over 10,000 signatures on a letter of support delivered to Governor Walz;
  • Resolutions passed or letters of support submitted by 90 elected officials, cities, townships & counties;
  • Public comments delivered by State, Federal & Local officials (38 in support and 3 in opposition);
  • The most extensive Environmental Impact Study in Minnesota history related to pipeline projects;
  • An agreement reached with the Fond du Lac Band for the replacement pipeline to cross the only Native American reservation on the route;
  • Between 2013-2015, Enbridge logged 242,125 field hours – equivalent to 27 years of study surveying wetlands and waterbodies, cultural resources, and threatened/endangered species, as well as countless consultations between federal and state agencies, landowners, and local units of government.
  • There have been 5,400 contacts with private landowners in 2017; Enbridge now has 99% landowner agreement with only 2 holdouts.

Line 3 has been the most planned and studied pipeline project in Minnesota’s history. What is even more clear through the process is that it’s time to build Line 3.

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There is a Consent Decree from the U.S. Government that says Line 3 needs to be replaced. What does this mean?

There is a “Consent Decree” from the U.S. Government that says Line 3 needs to be replaced. What does this mean?

The issue of what is best for Line 3 is something that has been discussed for years.  After looking into different options, the Department of Justice and the Environmental Protection Agency in 2016, under the Obama administration, reached a settlement agreement with Enbridge that concluded Line 3 must be replaced. A consent decree laid out the terms of the settlement, stating:

“Enbridge shall replace the segment of the Lakehead System Line 3 oil transmission pipeline that spans approximately 292 miles from Neche, North Dakota, to Superior, Wisconsin,”

“Enbridge shall complete replacement of Original US Line 3 and take Original US Line 3 out of service including depressurization of Original US Line 3, as expeditiously as practicable after receiving required regulatory approvals and permits for new Line 3.”

What is a consent decree? USLegal.com defines it as:

A consent decree is governed by federal and state laws, which vary by jurisdiction. It is generally a voluntary agreement worked out between two or more parties to a dispute. It generally has the same effect as a court order and can be enforced by the court if anyone does not comply with the orders.

To comply with the consent decree, Enbridge has worked hard for years with regulators at all levels to move the Line 3 replacement project forward.

The consent decree has been an important factor and part of this process.  In June of 2019, when the Minnesota Court of Appeals decided that further study was needed for the project’s Environmental Impact Statement, Judge Francis Connolly noted the importance of following the consent decree in his dissenting opinion:

“Existing Line 3 has been in operation since the 1960s, has suffered a high amount of corrosion and long-seam cracking, and must be replaced under a consent decree between Enbridge and the Environmental Protection Agency and Coast Guard.”

It is important to know that the federal government’s consent decree requires Line 3 to be replaced. In its unanimous decision to approve the project, the Minnesota Public Utilities Commission agreed with the same position already taken years earlier by the Environmental Protection Agency and Department of Justice on the necessity of replacing Line 3.

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Minnesota is known for being a very civically respectful community. How are actions by opponents to Line 3 fitting in with this tradition?

Minnesota is known for being a very civically respectful community. How are actions by opponents to Line 3 fitting in with this tradition?

The Line 3 replacement, like many other complex issues, continues to generate strong, passionate opinions both in support and in opposition to the project. Throughout the process, Enbridge has worked hard to respectfully listen and work with communities along the route.  The company has made adjustments to the plan whenever possible based on concerns that have been shared with the company. Enbridge’s efforts to work with the community and listen to concerns have included:  

  • Holding over 3,000 meetings with local officials, community leaders and other stakeholders since 2014.
  • An approved route that reflects years of environmental and cultural studies plus extensive engagement efforts that have resulted in more than 50 route changes to the line.
  • The largest cultural resource survey of its kinds along the route, in collaboration with tribes.

Tens of thousands of people have voiced their support for Line 3 in respectful ways, such as attending meetings, writing letters of support, signing petitions, and displaying lawn signs.

In contrast, how have the opponents to the Line 3 replacement acted?

While some have undoubtedly voiced their disagreement in a respectful manner, unfortunately others have resorted to rude, vulgar, militant, and damaging tactics.

Despite all of Enbridge’s efforts to engage in peaceful and respectful dialogue, opposition groups continue to attack Enbridge property and property that belongs to others who have no connection to the project.  They have also unfortunately disrupted local communities, harmed other businesses, and forced law enforcement and others to spend time dealing with protests instead of serving the broader community.

These actions have gone beyond civil discourse and have included:

In addition to what they’ve already done, opponents have repeatedly threatened to bring to Minnesota the large-scale protests similar in nature to the recent Standing Rock protests in North Dakota. The people of North Dakota were left to deal with the aftermath which resulted in 48 million pounds of garbage and debris, along with $38 million in police and cleanup costs. On multiple occasions, Winona LaDuke, Executive Director of Honor the Earth and prominent leader of opposition to Line 3, has threatened to lead and bring similar protests in Minnesota:

“Minnesota did not want Standing Rock, but this is their Standing Rock. They will have it,” she said. “They could have done the right thing, and they would not have this conflict. But be prepared, because we are preparing.” (Source) 

“If that permit is issued, you can be sure you will have Standing Rock in Minnesota. I will tell you that,” “We’ve been very clear with the state representatives, and the governor of Minnesota, that if they approve this line, there will be tens of thousands of people in Minnesota.” (Source)

In a piece titled Committed to Our Communities: Enbridge’s Culture of Listening, Enbridge’s Vice President of Major Projects John Swanson describes the company’s position on addressing disagreement about the project:

“At Enbridge we also hear what people are saying, because we live here. Locally, Enbridge is a company made up of your neighbors, your friends, your relatives. We understand Minnesota’s culture of respectful discourse, honest conversation, and talking through areas where we don’t agree. That’s why we’ve made a point of engaging people, listening to their views, and respecting their concerns. This engagement has resulted in more than 50 modifications to our proposed route, and we want this dialogue to continue well into the future.”

It’s important that all Minnesotans work together to follow our laws and processes, and that arguments are made respectfully, rather than with yelling, disrespect, and destruction.

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How many public comments were received in support and opposition to Line 3, and where were they from?

How many public comments were received in support and opposition to Line 3, and where were they from?

For over four years Line 3 has been reviewed, nearly 72,000 comments about the project have been submitted.  People opposed to Line 3 often claim that around 68,000 of the comments were from people opposed to the project.  What opponents are not telling you is that:

  • Most of these comments came from outside of Minnesota, and from states that don’t even border Minnesota, such as California, Florida, New York, and Massachusetts.
  • Most of these comments were from internet petitions targeting people across the country.
    • 28,000 came as signatures to an anonymous online petition based on “unique” email addresses.
    • 38,375 were signatures to a change.org petition from Youth Climate Intervenors coming from 20 different countries.
    • Of nearly 68,000 comments only 1,923 of these comments were verified to be from actual Minnesotans.

So what do actual Minnesotans think about the project?  

  • Approximately 15,000 people who actually live in Minnesota signed a letter to Governor Walz supporting the Line 3 project.
  • Over 11,000 people who live in Minnesota submitted comments to the DNR in support of the project.
  • There have been resolutions of support from over 90 Minnesotan companies, units of government, and local organizations.
  • No counties along the route have opposed the project.
  • Agreements with over 95% of private landowners have been secured along the preferred route.

For a project that directly impacts Minnesotans, we believe it’s the voices of real Minnesotans that matter – not the voices of activists from around the country or world who want to stop any legal process by recruiting people who will always oppose any kind of oil project regardless of the circumstances and facts.

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Does Minnesota really need and use the oil from Line 3? What do Minnesota's refineries say?

Does Minnesota really need and use the oil from Line 3? What do Minnesota’s refineries say?

Minnesota has and will continue to need and use oil that comes to our state through the Line 3 pipeline. It is an integral component in delivering the energy demand for Minnesota and the surrounding region.  Minnesota’s two refineries, Flint Hills in Rosemount and Marathon in St. Paul Park, produce fuels for cars, trucks, and planes that Minnesotans use every day. The refineries also produce other petroleum products such as asphalt that is used in road construction projects.  If the refineries struggle to get enough oil, it will make road construction projects across Minnesota more expensive.

Today, Line 3 is only operating at approximately half capacity, and Enbridge has provided multiple detailed forecasts showing that there is and will be demand in Minnesota by local refineries for the restored capacity on the Line 3 replacement for years to come.

Minnesotans use more than 12.8 million gallons of petroleum products every day provided by our two refineries that are dependent on oil from Line 3. One hundred percent of pipeline-delivered Canadian crude oil supplied to Minnesota refineries comes from the Enbridge system. Minnesota House of Representatives Research Department has noted:

  • “Minnesota has no indigenous sources of petroleum, so it must import both crude oil and refined oil products for use by its residents.”
  • “Minnesota has two petroleum refineries, which produce more than two-thirds of the state’s petroleum products. Seventy percent of these products are refined from Canadian crude oil, supplemented by supplies from North Dakota’s Bakken field.”
  • “The Flint Hills Resources refinery supplies about half of Minnesota’s motor fuel and 40 percent of Wisconsin’s, as well as the bulk of jet fuel for the Minneapolis-St. Paul International Airport.”

The Minnesota Department of Commerce was wrong when it said that Flint Hills and Marathon refineries are adequately supplied for their needs. Flint Hills Resources, the owner and operator of the Pine Bend Refinery in Rosemount, MN, noted that no one from Flint Hills was interviewed by anyone from DOC for information about their refinery, its capacity, or its needs for  a reliable source of oil. In May of 2018, Flint Hills Resources sent a letter to the Minnesota Public Utilities Commission with multiple statements in support of the Line 3 replacement project:

  • The Pine Bend refinery “produces most of the transportation fuels used in Minnesota, including nearly all the jet fuel, and a significant portion of the fuels used in the surrounding states.”
  • “The Pine Bend refinery relies exclusively on the Enbridge pipeline system to provide the crude oil it needs to help meet demand for all these products.”
  • The importance of the Enbridge pipeline system to Minnesota, including the proposed replacement of Line 3, cannot be overstated. Flint Hills Resources has submitted multiple letters attesting to this fact and underscoring why replacing Line 3 is necessary.”
  • “Flint Hills Resources strongly disagrees with the ALJ’s assertions that Minnesota shippers such as Flint Hills Resources have sufficient crude oil supplies to meet their needs.”
  • “Neither the ALJ or the Minnesota Department of Commerce has properly assessed the harm chronic apportionment on the Enbridge system poses to Minnesota shippers. Contrary to the ALJ’s opinion, apportionment is already adversely affecting Minnesota refineries. Last year, apportionment averaged nearly 20 percent on Enbridge’s heavy crude oil pipelines. Since January 2018, apportionment on these pipelines has averaged 45 percent, surging as high as 51 percent, which means during this time only a fraction of the crude oil refineries such as Pine Bend sought to purchase was able to be delivered. It also means apportionment is getting worse. These pipeline constraints force refineries to either slash production, draw down crude oil inventories (at a risk to operational reliability; this also assumes apportionment eases quickly enough to allow supplies to be replenished), or purchase crude oil already in the pipeline from other shippers at a higher price than that shipper’s alternative crude oil source, which would inflate the cost of crude oil for shippers that don’t have competitive alternatives. This is especially harmful to Minnesota’s land-locked and pipeline-dependent refineries where apportionment or the lack of adequate pipeline capacity, if left unremedied, will add unnecessary costs and create greater business risk, stymieing future refinery investments, costing jobs, and potentially leading to less reliable fuel supplies and less competitive prices for Minnesotans at the pump.”
  • “The replacement of Enbridge Line 3 is critical to maintaining proper crude oil supplies and addressing apportionment, which will continue to worsen to the detriment of Minnesota refineries, if left unresolved.”

Energy consultant Neil Earnest, president of Muse, Stencil & Company has also filed testimony on behalf of Enbridge. Earnest stated, “My analysis indicates that this situation will get worse as we move through time, and that the Minnesota refiners will experience more difficulty over time getting the crude oil via Enbridge, unless Line 3 is replaced.”

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How do pipelines like Line 3 compare to other ways of transporting oil in terms of safety and efficiency?

How do pipelines like Line 3 compare to other ways of transporting oil in terms of safety and efficiency?

When it comes to the transportation of oil, pipelines have been found to be much safer transportation than trucks or rail, and with reduced pipeline capacity there is increasing use of rail, resulting in a higher risk of a spill or incident, such as in June of 2018, when approximately 230,000 gallons of crude oil spilled into floodwaters in northwestern Iowa as a result of a train derailment.

A study by the Manhattan Institute concluded that transportation of oil and gas by pipelines results in fewer spillage incidents and injuries than road and rail, and noted that “Americans are more likely to get struck by lightning than to be killed in a pipeline accident.”

Transportation by road was found to have the highest incident rate (at 19.95 per billion-ton miles per year), followed by rail at 2.08, natural gas pipelines at 0.89, and hazardous liquid pipelines at 0.58. The study concluded: “The evidence is clear: transporting oil and natural gas by pipelines is safe. Furthermore, pipeline transportation is safer than transportation by road, rail, or barge, as measured by incidents, injuries, and fatalities – even though more road and rail incidents go unreported.”

A study by the Fraser Institute also supported this finding, noting that rail is more than 4.5 times more likely to experience an incident in the transportation of oil.

Why are pipelines so much safer? Pipeline companies take active preventative measures ensuring that safety and environment concerns are constantly addressed throughout planning, design, construction, and operation. This includes ongoing integrity management programs that consist of evaluation, inspection, and maintenance of the lines. Today, pipelines are built better than ever and are getting even safer – using new inspection and prevention technologies.  As a result, the number of significant pipeline incidents has dropped 32% since 2011. From 2008 through 2017, Enbridge has moved over 22 billion barrels of crude oil and liquids with a safe delivery record of 99.99966%.

At a time when issues related to climate and environment are of great importance, pipelines have a lower carbon footprint than rail transport of oil. A study by the University of Alberta concluded that pipelines create between 61 to 77 percent less greenhouse gas emissions than rail when transporting large capacities of crude oil over long distances.

Unfortunately, with reduced capacity on Line 3 and delays to the replacement project, oil  transported by rail is now at an all-time high.

The oil Minnesotans depend on is going to be transported here with or without Line 3.  A quick look at these facts shows again that it makes sense to move it in the safest way possible: in a state-of-the-art Line 3 replacement pipeline.

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If we're transitioning to greener energy, why should we build more fossil fuel infrastructure like Line 3?

If we’re transitioning to greener energy, why should we build more fossil fuel infrastructure like Line 3?

Minnesota and the rest of the country is making important progress toward a greener energy future that will expand the use of sustainable energy sources.  The challenge is how do we both maintain the economy we depend on today while at the same time support the important change that is happening.

There will be a time when green and renewable energy will be the primary way we power our homes, businesses, and communities.  The reality is that scenario is still decades away, making it important to have the energy we need today and in the immediate future to make this transition successful.  Projects like replacing Line 3 are still essential and will be for quite some time. 

Brad Shamla, Vice President of U.S. operations for Enbridge talks about this in a Star Tribune piece about how the Line 3 replacement is in line with goals to reduce greenhouse gas emissions while also meeting energy demands:

  • Minnesotans currently use over 12.8 million gallons of petroleum products every day, 2/3 of which come from Minnesota’s two refineries. Eighty percent of these come from Canadian crude oil, which all comes from Enbridge’s system.
  • A study by the International Energy Agency suggests that in 2040 48% of global energy demand will still be met by oil and gas, while meeting the reduced greenhouse gas emissions in line with the Paris Agreement.
  • Continued innovation has led to greenhouse gas emissions from the Alberta oil sands falling by 21% since 2019, with more improvements to come – some of this production is already lower than the average refined barrel in North America.
  • Electricity for powering the new Line 3 Replacement will be supplied by renewable energy sources.
  • Replacing Line 3 will have little impact on oil sands production – if not sent by pipeline, this oil will be shipped by rail, which is a less energy-efficient and more carbon-intensive method.

The oil that Line 3 brings to refineries will continue to be needed, as will the fuel and other products produced when the oil is refined.  Enbridge’s Line 3 Replacement Project  will make sure oil will be transported more efficiently, with a lower carbon footprint.

Beyond the fact we will continue to need fuel for cars, trucks, and airplanes, there are also many other uses for petroleum products that will also be needed for years to come. Jason Hayes, of the Mackinac Center for Public Policy summarizes these uses:

“Petroleum is the base of many products we use today, including transportation fuels, electricity, plastics, synthetic rubbers, chemicals, medicines and toiletries. All but the most basic of North American activities would cease without it. Additionally, we need fossil fuels to make many products that are not petroleum-based, including minerals and agricultural products. Only the most rudimentary, locally produced products would be available to us without oil and natural gas.”

Finding more efficient, sustainable means of energy production is a very important goal to keep working toward, but we also can’t ignore the reality of how important petroleum products are and will continue to be for a long time in so many facets of our modern lives.

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If you care about protecting water and natural resources, how can you support Line 3?

If you care about protecting water and natural resources, how can you support Line 3?

Minnesota can have both a safe way to transport energy and protect our natural resources.  Replacing Line 3 is an important step in ensuring these realities and another reason to move the project forward.

A lot of thought and planning was invested into the route selection for the Line 3 Replacement Project., State and federal regulations, along with agency, tribal, landowner, and other stakeholder input were all taken into account. After a general route location was identified, Enbridge conducted detailed environmental surveys to refine the route even further so as to avoid and minimize human and environmental impacts and to plan appropriate measures to minimize impacts in construction and operation.

Enbridge  will employ planned measures to minimize impact and protect the environment. Enbridge will retain environmental inspectors who will ensure that contractors abide by all regulatory requirements and permit conditions, and the project will be supervised by third-party environmental monitors who will register any concerns to appropriate agencies.

The existing Line 3 is over 60 years old, meaning there is a much higher chance of a spill with the existing line than with a new state-of-the-art pipeline will. The new pipeline would have the technology to detect a possible leak much faster than the old, making it easier to prevent disasters if they were to happen.

The replacement of Line 3 will be the safest way to continue providing Minnesotans the energy it needs while protecting our treasured natural resources.

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How in depth was the study to determine the environmental impact of Line 3?

How in depth was the study to determine the environmental impact of Line 3?

The Line 3 replacement is the most studied pipeline project in Minnesota’s history.  State agency staff spent 16 months drafting, in accordance with law, the 5,000 page analysis Environmental Impact Study (EIS). Forty-nine public meetings were held with multiple comment periods in which all input was gathered and included in the report.

Before the EIS was even started, from 2013 through 2015, 306 Enbridge field staff spent 242,125 hours (equivalent to 27 years of study) surveying wetlands, water bodies, cultural resources, and endangered species to help determine a preferred project route that minimizes potential impacts to people and the environment.

Why is an Environmental Impact Statement required? As explained on the Minnesota Public Utilities Commission website:

The Minnesota Environmental Policy Act (MEPA) requires that an environmental impact statement (EIS) be prepared for major governmental actions that have the potential for creating significant environmental impacts. To fulfill its MEPA responsibilities, the Commission has authorized the preparation of an EIS that addresses Enbridge’s Certificate of Need and Route Permit applications. The Commission has authorized The Department of Commerce’s Energy Environmental Review and Analysis (EERA) Unit to prepare the EIS, in cooperation with the Minnesota Department of Natural Resources and the Minnesota Pollution Control Agency. 

The Minnesota Public Utilities Commission website also outlines the in depth process leading up to the PUC approving the Final EIS for Line 3 (emphasis added):

  • In August 2015, the Department of Commerce conducted 15 public information meetings in 10 different counties in connection with the scoping process for the comparative environmental analysis that was to be prepared at that time. The scoping period included a 72-day comment period.
  • In April 2016, the Department of Commerce issued the Environmental Assessment Worksheet and the Draft Scoping Decision Document for the Line 3 Project. The Department of Commerce also conducted 12 EIS scoping meetings in 10 different counties. The scoping period included a 45-day comment period.
  • In November 2016, upon completion of EIS scoping, the Commission approved the EIS scoping decision proposed by the Department of Commerce and forwarded one system alternative, four route alternatives, and 24 route segment alternatives for further consideration during the contested case proceedings.
  • On December 5, 2016, the Department of Commerce issued the EIS Scoping Decision Document and the EIS Preparation Notice. The EIS Preparation Notice signals the start of preparation of the Draft EIS, and start of the 280-day timeline in which a determination of adequacy must be made.
  • On May 15, 2017, the Department of Commerce released the Draft EIS.
  • In June 2017, the Department of Commerce held 22 public information meetings in 22 different counties. The purpose of the meetings was to provide an overview of the Draft EIS and allow interested persons to ask questions and provide oral and written on the Draft EIS. A comment period following the meetings was open until July 10, 2017.
  • On August 14, 2017, the Commission issued an order that: 1) extended the 280-day statutory deadline for completion of the Final EIS by the consent of the parties; 2) referred the matter of Final EIS adequacy to a second ALJ, and requested the judge develop a record and issue a report and recommendation; and 3) established a procedural schedule for the adequacy determination. 
  • On August 17, 2017, the Department of Commerce released the Final EIS. A comment period was open until October 2, 2017, to receive comments on the adequacy of Final EIS. 
  • From September 26, 2017 through October 25, 2017, the Commission held 16 public hearings in eight different counties. The public hearings were conducted by an Administrative Law Judge (ALJ) from the Minnesota Office of Administrative Hearings. A comment period was open until November 22, 2017, to receive comments on the certificate of need application and the route permit application for the proposed Line 3 project.
  • On November 1, 2017, the second ALJ filed his report concerning the adequacy of the Final EIS. The ALJ recommended that the Commission find the Final EIS adequate.
  • On December 14, 2017, the Commission issued an order which concluded that the Final EIS could not be found adequate until it contained specific additional information. The Commission requested the Department of Commerce to prepare the additional information and submit to the Commission by February 12, 2018.
  • On February 12, 2018, the Department of Commerce issued a revised Final EIS.
  • On May 1, 2018, the Commission issued an order finding the revised Final EIS adequate.

The approved Final Environmental Impact Statement (FEIS) was 13,500 pages in length. It is the result of extensive work between different agencies including the environmental branch of the Department of Commerce (DOC), the Minnesota Pollution Control Agency, and the Department of Natural Resources.  Regulators reviewed it and approved the EIS’ adequacy, meaning they believed the report had fully examined and reviewed all of the issues and other element of the project.

Line 3 opponents appealed the adequacy decision and asked the courts to review the matter. In June of 2019 the Minnesota Court of Appeals rejected 8 of the 9 disputes raised by these groups, but identified one issue with the EIS that the court believed needed further analysis: addressing the potential impact of an oil spill into the Lake Superior watershed.

Excerpts from Judge Francis Connolly’s dissenting opinion indicate why this additional review is not necessary:

“I respectfully dissent. I do not believe that the decision of respondent Minnesota Public Utilities Commission (commission) was arbitrary and capricious or unsupported by substantial evidence. Relator Honor the Earth (HTE) contends that the final environmental-impact statement (FEIS) failed to consider the effect of oil spills on the Lake Superior watershed. HTE is wrong. It did.”

 “The FEIS was thoughtfully prepared by the Minnesota Department of Commerce’s Energy Environmental Review and Analysis division (DOC-EERA) with assistance from other responsible agencies. It consists of 13 chapters, 21 appendices, and thousands of pages that address the potentially significant issues and alternatives raised in scoping. It was subjected to extensive public hearings and comments. It was thoroughly reviewed and determined adequate both by an experienced administrative-law judge (ALJ) and a unanimous commission.”

“While I agree that the FEIS needed to address the concerns raised in scoping, which committed it to “consider potential impacts to Lake Superior watershed,” I would nonetheless conclude that the representative-modeling approach sufficiently considered the effect of oil spills on the Lake Superior watershed.”

“But Minn. R. 4410.2800 does not state that issues must be addressed “specifically” and the FEIS did address the concerns about the Lake Superior watershed. The FEIS simply addressed it in a manner different from how HTE wanted. But as an appellate court, we cannot substitute our own judgment for the judgment of the DOC-EERA, DNR, MPCA, the experts tasked with drafting the FEIS, and finally the commission when that judgment is reasonable and supported by the record. This is not was our standard of review dictates.”

“In conclusion, by according substantial deference to the commission’s decision as required by precedent, I would affirm the commission’s decision that the FEIS is adequate D-12 because the representative-modeling approach sufficiently considers “potential impacts to the Lake Superior watershed” as required by the FSDD and the record reflects a reasoned determination of why that approach was used. Therefore, the commission’s decision is not arbitrary or capricious and is supported by the record. Consequently, I must dissent.”

The DNR and MPCA have since released a statement saying that although they will not take final action until the EIS is revised, the agencies will still continue their work on the permit applications.

The Public Utilities Commission decided not to appeal the court decision about the EIS.  They remain concerned about the need to keep the process moving and will revisit their environmental review of the project to include more analysis of the potential impact of a spill in the Lake Superior watershed.

After years of study by Enbridge, the Department of Commerce, the PCA, and the DNR, the Line 3 Replacement Project is now by far the most studied pipeline in Minnesota’s history. The additional work on the EIS will make an extremely thorough study even more thorough.

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What will happen to Line 3 if it is not replaced?

What will happen to Line 3 if it is not replaced?

If Line 3 is not replaced, the existing pipeline, originally built in the 1960s, will still continue to operate.  Right now, Line 3 only carries about half of the amount of oil it was originally designed to transport.  At the same time, oil production in North Dakota and Canada continues to increase, putting pressure on the system we use to get oil to market.

If Line 3 is not replaced, continued operation of the existing pipeline will require thousands of preventative maintenance digs to keep it running safely.  This will do nothing to reduce the quantity of oil that is being transported less efficiently and less safely by rail.

These integrity digs are precautions to identify and examine any potential needed repairs;  Enbridge.com explains how integrity digs work:

Enbridge’s regular monitoring and inspection program alerts us to pipeline features that may require a visual inspection to determine if a repair or other action is required. Features that have been known to require a repair in the past include third-party excavation damage, corrosion (a chemical reaction between the environment and the pipeline steel that reduces the pipe wall thickness), and cracking or denting. A preventative maintenance dig is the method we use to make the visual inspection. Each dig involves excavating a section of buried pipe such that we can carefully clean and examine it. If we find a defect, we repair it, recoat and re-bury the pipe. In some cases, we cut out old sections of pipe so we can weld in new pipe. A preventative maintenance dig can take from two days to two weeks, depending on the nature of the feature and the results of the visual inspection.

Enbridge has estimated that over the next 15 years, Line 3 would require as many as 6,000 of these integrity digs and other repairs along the line. While these digs are important, they can cause disruption to landowners and communities along the route.

Reduced pipeline capacity today has resulted in more crude oil being shipped by trains. If Line 3 is not replaced, with the current Line 3 operating at only half capacity, the oil that could have been transported at full capacity will continue to be transported by rail instead.

The existing Line 3 can be operating safely, but with limited capacity and significant maintenance, the best way forward is to make a safe pipeline even safer by replacing Line 3.

Additional Information:

Line 3 had an accident in Grand Rapids, MN in 1991. How do we know something like this won't happen again?

Line 3 had an accident in Grand Rapids, MN in 1991. How do we know something like this won’t happen again?

Enbridge did have a release in Grand Rapids, MN in 1991, but the oil was quickly and thoroughly recovered and there was no permanent damage to the Mississippi River. In fact, this year, that area of the river has been identified by the Minnesota Pollution Control Agency as one of the cleanest and most pristine portions of the river in the state.

Technology has improved significantly to help prevent accidents like this from happening, and if they do happen, to be able to quickly stop the accident from being catastrophic. Replacing Line 3 will ensure the latest technology will be applied to the Line 3 project and the new pipeline.

Between 2008 through 2017 Enbridge has transported over 22 billion barrels of crude oil and liquids with a safe delivery record of 99.99966 percent.  Enbridge’s goal is to strive for zero incidents. From 2011-2016, Enbridge spent $5.15 billion on system integrity and leak detection across their crude oil and liquids pipeline operations. This investment is just one way that Enbridge meets and exceeds government regulations with the latest technology for prevention, monitoring, and emergency response:

Prevention:

  • Careful selection and testing of pipe prior to and during manufacture
  • X-Ray and Ultrasonic testing of all welds made to a pipeline
  • Durable coating systems to protect pipe from corrosion and corrosion inhibitors
  • Preventive maintenance digs for any identified features that need closer visual inspection

Monitoring:

Emergency Response:

  • On-call, 24/7 protocol in place for rapid response to any incident
  • Equipment and resources available along the Line 3 right-of-way

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How important is Line 3 to Minnesota's economy?

How important is Line 3 to Minnesota’s economy?

Line 3 is an integral part of Enbridge’s mainline system. It helps ensure that Minnesota and the surrounding region are connected to a secure and reliable supply of North American crude oil. Line 3 is already an important part of Minnesota’s economy at the state, county, and local community level.  In 2018, Enbridge paid over $30M in property taxes to the State of Minnesota; since 2015, contributed over $3M in community investments through their Ecofootprint Grant program; has over 350 Minnesota-based permanent and temporary employees and supports thousands of jobs at refineries as well other parts of the economy that depend on having reliable fuel and energy.

The construction work to replace Line 3 will be a $2.9B private investment in the U.S., that is approximately two and a half times the size of the US Bank Stadium project. There is no taxpayer money funding the Line 3 construction project.

Line 3 Replacement project’s impact on Minnesota’s economy:

  • Infrastructure Investment: Line 3 represents a $2.6 billion investment in Minnesota, this will be the largest privately financed construction project in the State’s history.
  • Jobs: 8,600 quality jobs will be created over a two-year period, including 2,800 hospitality jobs, 4,200 construction jobs (half expected to be filled locally), and 1,600 jobs in other sectors.
  • Long-term property tax revenue: Enbridge pays more than $30 million in Minnesota property taxes annually; this will increase incrementally by $35 million beginning the first full year of service.
  • Local Economic Activity: There will be a significant boost to the economy during construction, as local hotels, restaurants, and other businesses along the route will benefit.
  • Support for Minnesota refineries: Line 3 will provide an energy savings on a per-barrel basis by reducing apportionments and ensuring a reliable source of crude oil delivery.

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How significant are the jobs needed to build Line 3 and to operate the pipeline?

How significant are the jobs needed to build Line 3 and to operate the pipeline?

The University of Minnesota Duluth did an economic impact analysis on the Line 3 Replacement project. As reported in Business North, the impact study found that the two-year construction phase of the Line 3 project will:

  • Produce an economic impact exceeding $2 billion in Minnesota. Of that amount,  $1.5 billion will be contributed by Enbridge.
  • Directly and indirectly support 8,600 jobs. They will include 4,200 construction jobs, 2,100 local of them in local communities and 2,100 non-local, support 2,800 retail/hospitality sector jobs and 1,600 local supplier/manufacturer jobs.
  • Contribute approximately $334 million in total employee wages and benefits.
  • Infuse $162 million (about 50 percent of total wages) for local workers.
  • Have a value added impact of $745 million on the region.
  • Add $162 million in total economic impact from non-local worker spending on meals, lodging, and incidentals while working in the study area.

The project will have a high number of skilled jobs and training that help build well-paying careers. When interviewed for WCCO Radio’s Fluence Forum, Kevin Pranis of Laborers’ International Union of North America (LIUNA) spoke about the types of quality jobs Line 3 will bring and the impact it will have on skilled labor:

“There’s a lot of skill involved, and when we talk about job numbers, it’s easy to throw those numbers around, but what’s most important to us is job quality. If you talk about the kinds of jobs that are created and the kinds of skills – these are part of a construction career. It’s not just a job, it’s not a temporary job, as it’s sometimes called.”

In addition, skilled workers in Minnesota’s refineries continue to depend on the oil provided by the Enbridge system and the increased capacity of the replacement Line 3. Jake Reint, from Flint Hills Resources explains:

“Our refinery is not a lot of good without the Enbridge system supplying it. So we’ve invested the equivalent of two Vikings stadiums in the last ten years. We have roughly a thousand employees on site, between 500 and 3,000 contractors on site on any given day depending on what’s going on. And these are skilled workers.”

The Line 3 replacement will provide thousands of quality jobs and an economic boost during the construction phase of the project, continue to support the workforce associated with the energy from Line 3, and provide a lasting investment in the careers of these workers.

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How would not replacing Line 3 impact Minnesota's economy?

How would not replacing Line 3 impact Minnesota’s economy?

Line 3 plays an important part in Minnesota’s economy both directly and indirectly. It directly supports jobs at two oil refineries while supporting a number of communities across Minnesota through property tax revenues it generates.  Indirectly, the energy it brings to Minnesota is used to help people and businesses across Minnesota live, work, and thrive.

Minnesota’s economy would be negatively impacted if Line 3 were not replaced. It will likely result in higher prices for fuel that will make it even harder for people already facing significant economic challenges to comfortably live.

The Institute for Energy Research has concluded that “Without sufficient pipeline capacity, consumers could face energy shortages and skyrocketing prices.” This limited capacity has an impact on Minnesotans, who use over 12.8 million gallons of petroleum products every day for vehicles of all kinds, from cars and trucks to planes, boats, ATVs, and snowmobiles. As transportation of oil by rail is less efficient than by pipeline, the added cost to delivery by rail can get passed on to refineries, and then to consumers. In addition, higher transportation costs also transfer to the cost of consumer goods.

Replacing Line 3 will restore it to its full capacity, reducing the need to rely on the more expensive rail transportation.

Additionally, by not replacing Line 3 it results in Minnesotans missing out on the economic boost from the project, which includes:

  • A private investment of $2.6 billion
  • An annual increase in property taxes of $19.5 million for communities along the route
  • 8,600 quality jobs
  • Boosts to economies along the route

From increased consumer costs to missing out on jobs, tax revenue, and boosts to local economies, not replacing Line 3 would have a negative economic impact on Minnesota.

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How will Minnesota benefit from Line 3 in terms of property taxes?

How will Minnesota benefit from Line 3 in terms of property taxes?

In addition to being a key part of Minnesota’s energy infrastructure, Line 3 is also an important part of the economy in many counties and communities along the right-of-way.  Things like pipelines, power lines and other utilities pay taxes to the counties and communities where they pass through.

Replacing the existing Line 3 with a new line will increase the line’s value and as a result, create increased property tax revenue for local governments.  This means the project will have a significant, lasting positive impact for communities along the Line 3 replacement route.

Enbridge currently pays more than $30 million in property taxes annually across Minnesota for pipelines and related facilities such as terminals, storage facilities, and pump stations. These property taxes will increase by approximately $19.5 million annually, beginning in the first full year that the Line 3 replacement is in service.

In some counties, Enbridge is the largest taxpayer where economic challenges exist.  This makes the pipeline and its future even more important.

These taxes will directly benefit communities along the route, providing extra funding for schools, infrastructure, and other important services. Paul Gerde, the chair of MN Rural Counties and Pope County Commissioner explains these positive impacts:

“Pipelines have become controversial in recent years, but largely lost in all the back and forth between individuals and groups that support or oppose this project and others like it, is that pipeline property tax revenues are the foundation for many rural county budgets, and they ease the burden on individual home owners and small business owners who pay the freight for county services.

At a time when the limited resources of counties across Greater Minnesota are being stretched thin from growing concerns related to opioid and eldercare abuse, an aging and increasingly isolated population, and endless unfunded mandates, pipeline revenues have supported law enforcement, human service and transportation infrastructure programs that have improved and saved lives. It is not an overstatement to say, pipeline revenue is lifeline revenue to many counties of the state.”

The Line 3 replacement project will benefit communities along the route with jobs and an economic boost during construction, but also with important funding for years to come.

Additional Information:

    How were concerns of tribal communities addressed throughout the Line 3 planning process?

    How were concerns of tribal communities addressed throughout the Line 3 planning process?

    Enbridge has worked closely with tribal communities on the planning of the Line 3 replacement – In fact, the project involves the most comprehensive Indigenous consultation and engagement initiative in Enbridge’s history.

    After meeting with the two tribes directly affected by the project, Line 3 will now follow an alternate route that avoids the Leech Lake reservation, and an agreement has been made with the Fond du Lac Band for passage through their reservation. In addition, Enbridge has earmarked $100 million in pipeline work for Indian contractors and employees, provides Indigenous awareness training to hundreds of employees, and is working with tribes to conduct one of the largest cultural surveys of its kind along the pipeline route.

    With support from Enbridge and other sponsors, the Minneapolis-based Building Trades Tribal Partnership Program provides Native Americans with training in pipeline construction. Many graduates are able to find immediate employment, including on Enbridge’s Line 3 Replacement Project facilities upgrade in Superior, WI.

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    What is being done to make sure that tribal cultural resources along the route are preserved?

    What is being done to make sure that tribal cultural resources along the route are preserved?

    The Line 3 replacement route will cross through 337 miles of northern Minnesota, an area that contains numerous archaeological resources of historical and cultural significance. To ensure that important artifacts and resources along this route are preserved, Enbridge has fully funded an unprecedented cultural resources survey along the route. This work was recently completed, and has resulted in changes to the route as needed.

    The Public Utilities Commission ruled that the survey must be complete before construction could begin. Originally, the Army Corps of Engineers had ordered a survey on 66 miles of the route. After tribes requested that 201 miles of the route be surveyed, Enbridge chose to fund a survey along the entire 337 miles of the route.  Work began in late 2017, and was completed by August 2018.

    Led by the Fond du Lac Band of Lake Superior Chippewa, the survey is the largest of its kind ever attempted in the energy industry, involving nine tribes participating directly, and over 30 tribes involved via the Army Corps of Engineers. Using GPS and oral histories from tribal leaders, the survey has uncovered sites and artifacts of cultural significance, including potential stone tools, human-made mounds, pottery, arrowheads, and a possible hidden village.

    Jim Jones, a project manager for the survey and member of the Leech Lake Band of Ojibwe explains the significance of this survey in a WCCO interview:

    “A project like this has never been done across tribal communities or with energy companies, and they really set a precedent. And for Fond du Lac to take the lead on that is really unique, working with Enbridge on that, is the first of its kind in the nation”

    As the construction phase of the project starts, tribal monitors will be hired to make sure that the identified cultural resources along the route are protected.

    Additional Information:

    Supporting tribal communities is an important part of the Line 3 project. How has Enbridge included and supported tribal communities in projects outside of Minnesota?

    Supporting tribal communities is an important part of the Line 3 project. How has Enbridge included and supported tribal communities in projects outside of Minnesota?

    Enbridge has worked extremely hard from the beginning of the Line 3 project to engage and support tribal communities across Minnesota.  This has included listening to their concerns and making changes in the project, to working on ways to ensure members of tribal communities are part of the workforce that will be needed to build the new Line 3.

    All of this is part of the company’s proven commitment to partner and support tribal communities wherever its lines are located.  What many in Minnesota have not seen is how strong this commitment is in communities where work and other projects have been completed.

    In Minnesota, Enbridge has pledged to allocate $100 million for tribal economic opportunities as part of the Line 3 replacement project. This would take the form of contracts with Native-owned businesses, employment of tribal members, and grants for workforce training.

    Opponents have raised questions about this pledge, challenging the company’s commitment and wondering how likely Enbridge is to follow through with their commitment.

    One only needs to look at recent construction on the Canadian portion of the Line 3 replacement and other projects in North America to see first-hand Enbridge’s commitment to tribal inclusion.  This is a great way to see how Enbridge views relationships with tribal communities and how they will deliver on their commitment to this essential project in Minnesota.

    Enbridge has worked closely with Indigenous communities in Canada, regularly dealing with 200 Indigenous communities throughout the country. The Canadian portion of the line 3 project, which was completed in May of 2019, had an unprecedented level of indigenous inclusion and participation, which included:

    • Engaging 154 Indigenous communities about the project
    • 98 indigenous communities or groups were signatories to agreements on Traditional Land Use, procurement, training and employment opportunities, environmental stewardship, and construction monitoring.
    • Indigenous brokers were used to recruit and identify job candidates in their regions
    • Supply chain processes required bidders to detail their plans for Indigenous inclusion when responding to Requests for Proposals
    • There was approximately $400 million of indigenous project spending, which included labor and contracting, capacity building and community sustainability initiatives. $116 million of this was wages to indigenous workers.
    • Over 1,100 indigenous workers were employed at peak construction (20% of the project’s total workforce)
    • Over 3 years, 260 indigenous workers graduated from Enbridge’s Pipeline 101 training-to-employment program.

    Lowa Beebe, public relations liaison with the Alberta office of the Assembly of First Nations (AFN) talked about Enbridge’s inclusion of Indigenous communities in the Canadian portion of the Line 3 Project: “I’m very honoured to be here today. I’m very honoured to bring an Indigenous voice today, and to actually say engagement is happening, and this is the way it should happen. Line 3 is unique. I want to stand here and celebrate today, and really say they’ve done a fantastic job, they’ve done a great job, and they’re continuing to do a job.”

    On Indigenous Peoples Day, Al Monaco, CEO of Enbridge wrote, “Building strong, trusting relationships with Indigenous communities, over time, is a precondition to doing business.” With the level of engagement involved in the Canadian portion of the project, and the plan to allocate $100 million for tribal economic opportunities for the Line 3 project in Minnesota, Enbridge is demonstrating that they walk their talk when it comes to tribal inclusion.

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    How does Line 3 benefit tribal communities?

    How does Line 3 benefit tribal communities?

    Replacing Line 3 will not only protect the environment, invest billions to support jobs and Minnesota’s economy; it will also help benefit and support tribal communities across the state.

    A key part of this is Enbridge’s Tribal Economic Opportunity Plan that commits the company to invest $100 million in tribal economic opportunities that includes contracts with tribal-owned businesses, a commitment to employ tribal members for construction and other aspects of work associated with the project and awarding grants for training and other programs that will benefit tribes and their members.

    The broader goal is to connect tribal communities with the jobs and economic opportunities that come from working on key projects like this.  Training people for a job as part of the Line 3 Replacement Project construction team will also prepare them for future jobs beyond the pipeline. Additionally, this ensures that people closest to the pipeline work close to home and businesses along the route see as much of the benefits as possible.

    Gordon Construction, an American Indian-owned company, is just one examples of a native-owned company that stands to benefit from the project having already received a contract to work on the pipeline project.

    Matt Gordon, Director of Operations for Gordon Construction and member of the White Earth Nation has expressed his support for the Line 3 and the jobs it will create for tribal communities:

    “I support the Line 3 project because it makes sense to replace something that is decades old and depended on each day. I support the project because it is a chance for my company to hire more people from White Earth and other tribal communities to do work that pays great and teaches a life-long skill.”

    As part of the exhaustive planning work for the pipeline, Enbridge is also funding one of the largest cultural surveys of its kind along the Line 3 Replacement Project route.  This important work helps develop and identify important information about the area and is being led by the Fond du Lac band. Jim Jones Jr., lead project manager for the cultural survey along the Line 3 Replacement route recently spoke on WCCO’s Fluence Forum about the impact of the survey work, and future Line 3 Replacement construction work on tribal communities:

    “Being involved in the Line 3 project has really opened my eyes to what are the opportunities for tribal members and community members to be involved.”

    “Looking beyond just gaming and tribal enterprises, and that type of investment gives those communities that opportunity that wasn’t there before, and so that really has a fiscal impact on those tribal communities. And working with the tribes I have this last summer, I’ve seen that firsthand. I’ve seen tribal members who were making these wages and moved themselves up, got a lot of things taken care of and have money put away. I’ve seen the positive impact and that was really encouraging to see that. A project like this has never been done across tribal communities or with energy companies, and it really set a precedent. And for Fond du Lac to take the lead on that is really unique, working with Enbridge on that is the first of its kind in the nation.”

    Enbridge is committed to making sure that the Line 3 Replacement Project creates jobs and future economic opportunities for tribal businesses and members while making sure we continue to have access to the safe, affordable energy that Minnesota needs.

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    Join these Minnesotans and support replacing Line 3

    Minnesotans for Line 3 supporters map

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    Continue to show your support by signing this letter to Governor Walz

    Thank you for your continued support of Minnesotans for Line 3. Please join us in adding your name and support to a letter that will be delivered to the Walz Administration in their first week of office. The letter highlights three reasons why Line 3 needs to be replaced and confirms Governor Walz’s continued support of the project:

    • The need to replace aging infrastructure
    • The thoroughness of the review process
    • The importance of investing in local jobs

    Governor Walz, please take action; join us with your continued support of replacing Line 3 and direct your agencies to finalize the permitting process promptly.

    Join 15,011 other Minnesotans by signing the letter today!

    SIGN THE LETTER BELOW

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    January 2019

    Dear Governor Walz and Lt. Governor Flanagan: We look forward to working with you and continuing to make northern Minnesota a great place to live, work and enjoy all that our natural resources have to offer.

    We are writing to you, during your first week in office, to convey our steadfast support for Enbridge’s Line 3 Replacement Project, and to ask you to respect the process by rescinding a last minute legal challenge from the previous Administration’s Department of Commerce of a reasoned review and approval of the project by that same Administration’s Public Utilities Commission.  We also ask you direct your agencies to finalize the permitting process promptly, to achieve construction in 2019.

    For four years, we watched this project – to replace aging infrastructure and further protect water quality in northern Minnesota — being evaluated. We heard Governor Dayton say “trust the process, trust the Public Utilities Commission.” So we did – and we participated.

    We went to the 65 public meetings (15 held on tribal reservations), we submitted comments to the official project docket, we attended events, we put signs in our yards, and we wrote letters to the editor in our newspapers. Our local governments and organizations passed more than 90 resolutions of support for the project. Enbridge reached agreements with the two tribes directly impacted by the project.

    Finally, after a robust evaluation and careful consideration of a voluminous record, the Governor Dayton-appointed PUC issued permits confirming a need to replace the pipeline by unanimous decision and issued a route informed in part by a thorough and robust environmental impact statement. The PUC reaffirmed their decisions on need and route, again by unanimous decision, in November and December 2018.

    After the most comprehensive review in the history of pipelines in Minnesota the previous Administration’s Department of Commerce filed a court challenge to its sister-agency, the PUC’s decision.

    Projects like replacing Line 3 do not come along very often. In anticipation of construction in summer 2019, our union halls are gearing up to put the local workforce to work near home. Our local businesses and companies are developing plans and considering the work force they will need to employ and accommodate to meet this economic boom. Our elected and public officials are creating budgets and determining where resources may be needed. This 350-mile project will provide so many benefits across northern Minnesota – all privately funded, infusing millions of dollars into our communities.

    As you enter office, we, as a collective coalition of northern Minnesota elected and public officials, business owners, labor unions, and citizens, ask your administration to ensure we all put safety first by replacing aging infrastructure and protecting our natural resources, while investing in family- and community-supporting jobs.

    With this in mind, we have three specific requests:

    1. We ask you to rescind the previous administration’s lawsuit against the Line 3 Certificate of Need and to move this project forward.
    2. We ask you to direct your agencies to finalize the permitting process promptly, to achieve construction in 2019.
    3. We ask you to join us in supporting the Line 3 Replacement Project.

    We are happy to discuss with you and your Administration how replacing Line 3 will benefit our communities.