PIPELINE PERILTar Sands Expansion

and the Threat to Wildlife in

the Great Lakes Region

ii | NATIONAL WILDLIFE FEDERATION

ACKNOWLEDGMENTS

AUTHORS

Shelley Kath

Paul Blackburn

Jim Murphy

REVIEWERS/EDITORS

Andy Buchsbaum

Lena Moffitt

Neil Kagan

Hope Lemieux

COVER PHOTOS

top background: Emily Stark; inset: National Transportation Safety Board

bottom from left: Gary Lackie/NWF photo contest, U.S. Fish and Wildlife Service,

David Kenyon, Michael Thomasson

This Report is available online at www.nwf.com/PipelinePeril

© 2014 National Wildlife Federation

NATIONAL WILDLIFE FEDERATION | 1

EXECUTIVE SUMMARY

From the skyscrapers of bustling Chicago to the remote, rocky shores

of Lake Superior, the Great Lakes region is one of America’s most

precious resources for people and wildlife. The Great Lakes directly

provide one in ten Americans with water for drinking and agriculture, and

offer countless opportunities to connect with the outdoors.1 Few places

on earth grant as many opportunities to enjoy wildlife from fishing to

bird watching to hiking. The Great Lakes region also provides a multitude

of sporting opportunities including sailing, kayaking, running, biking and

skiing along the gorgeous shores of these immense fresh water seas. The

Great Lakes are the largest unfrozen freshwater source in the world and

the region provides valuable habitat for iconic species like Moose, Lynx,

Wolves and Loons, as well as endangered species like the beautiful Karner

Blue Butterfly, Cerulean Warbler and prehistoric Lake Sturgeon.2

Yet, a growing threat looms, putting the health and future of the Great Lakes region at grave risk.

The region is encircled by a vast array of pipelines sending toxic, spill-prone, and impossible-to-clean-

up tar sands oil through the Great Lakes region. Tar sands oil is a carbon-intensive, sticky substance

that is mined and drilled from deposits in the evergreen forests and rich wetlands of Northern

Alberta. This substance is eventually refined into gasoline, jet fuel, and other transportation fuels.3

Tar sands oil poses several direct threats to the Great Lakes region:

➤ TOXIC TAR SANDS OIL SPILLS AND OIL TRAIN EXPLOSIONS. With pipelines throughout

the Great Lakes region, the threat of catastrophic tar sands oil spills imperils extensive habitat

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and water supply areas. The Great Lakes region has already suffered a horrific spill in 2010,

when nearly a million gallons of tar sands oil spilled into the Kalamazoo River.4 Thousands of

birds, turtles, and small mammals, such as Beavers, were affected by the spill, and many died.

Portions of a 40-mile stretch of the Kalamazoo River are still polluted and will likely be affected

for decades. Tar sands oil pipelines currently threaten areas where wildlife thrive such as the

Chippewa National Forest, Saint Louis River Estuary, and Necedah National Wildlife Refuge.

Plans are currently being drawn up to allow tar sands oil to enter the Great Lakes region via

tanker and some is already starting to come in by rail.5 Such threats pose further spill risks to

the Great Lakes region. The tragic explosion in Lac Mégantic, Quebec last summer resulted in

the deaths of 47 people and destruction of the town.6 While it was not tar sands oil, this example

shows the extreme threats that increased oil transportation by rail and other modes pose to the

Great Lakes region and the surrounding communities.

➤ CLIMATE IMPACTS. Tar sands oil is far more carbon polluting than conventional fossil

fuels, with up to a 37% higher life-cycle basis than regular oil.7 The tar sands oil industry

currently plans a massive expansion of the mining and export of tar sands oil provided they

are able to transport their product to market. These tar sands oil transportation projects and

the development they will trigger will serve to lock in run-away climate change. The Great

Lakes region has already begun seeing the harsh impacts of climate change, such as reduced

water levels (due in particular to decreased winter ice cover allowing more evaporation),

increased frequency of intense storm events (altering the timing of inflows), and warmer water

temperatures, all of which feed massive toxic algae blooms.8 Toxic algal blooms make recreation

in the Great Lakes dangerous, smelly and unpleasant, and can also cause fish and wildlife dead

zones in the usually productive Great Lakes.9 These harms will plague the Great Lakes region

and harm the wildlife that depends on it if climate change is not curbed.

 

 

 

 

 

 

 

 

 

 

 

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  Oil Refinery

Oil Terminal

Treasured Habitat Areas

Drinking Water Supply

Possible Expansions

Public Expansions

No Change

NATIONAL WILDLIFE FEDERATION | 3

➤ DIRTY REFINERIES. More tar sands will mean more pollution

from the oil refineries processing tar sands oil throughout the

region. Unrefined tar sands oil is heavier and contains substantially

more toxins than conventional oil, resulting in a more intensive and

polluting refining process. These pollutants may be released into

the communities surrounding the refineries, harming wildlife and

jeopardizing the health of people living nearby. Refining tar sands oil

also creates a harmful, coal-like solid byproduct called petroleum coke,

or petcoke. This byproduct is often stored in massive, uncovered piles

outside of refineries, frequently along rivers, allowing dust from the

piles to contaminate neighboring rivers and communities. Petcoke can

also be burned to create electricity, releasing more carbon pollution

into the atmosphere and further exacerbating all the negative impacts

of climate change.10

These threats will grow if the tar sands oil industry is allowed to expand.

The tar sands oil industry is seeking to send even more tar sands oil

through the Great Lakes region in an attempt to move its product

abroad and receive top market prices. Chiefly, the industry is seeking to

approximately double the amount of tar sands oil that crosses the border

along a pipeline

called the Alberta Clipper.11 The Alberta

Clipper pipeline is the aorta of Enbridge’s

pipeline system, which winds through the

Great Lakes region. This expansion would

allow the industry to push forward plans to

transport tar sands oil to key export points on

the Gulf Coast and East Coast.

Despite committing to a public process of

review and permitting before any tar sands oil

expansion in the Great Lakes region involving

the Alberta Clipper would be decided upon,

the State Department recently approved a

behind-the-scenes scheme by Enbridge to

almost double the amount of tar sands oil

The tar sands oil industry is seeking to send even more tar sands oil through the Great Lakes region in an attempt to move its product abroad and receive top market prices.

Canada

U.S.

Line 67

450,000 bpd limit

New 36-inchPipeline

New 36-inchPipeline

New Border Segment

(34-inch diameter)

Bypass Project (800,000 bpd)

New Pipeline Not drawn to scale

ExistingLine 3

Enbridge has hatched an illegal scheme to try and avoid review of the impacts of tar sands expansion to wildlife and natural places in the Great Lakes region by manipulating border f lows on parallel pipelines. However, this scheme clearly violates the need for public review and is being challenged in court.

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moving into the Great Lakes region. This scheme would temporarily divert the flow of tar sands oil

from the Alberta Clipper to a new pipe segment that would replace the border crossing of an older

parallel line, which had been used for moving conventional oil.12 This approval occurred with no

public process or input,13 undermining the public review process and the legal permitting process

the State Department had committed to follow. A diverse coalition of indigenous and conservation

groups are challenging this illegal approval in court.

Something can be done. The State Department must reverse this decision, prohibit

Enbridge from moving forward with any capacity increase until the current public review process is

completed and ensure the President’s climate test is applied to any plan to increase the amount of

toxic tar sands entering the Great Lakes region.14

This report details the threat of tar sands oil expansion to the wildlife and people of the Great

Lakes region and explains why tar sands oil expansion presents too high a risk. Fortunately, concern

over the threat of tar sands is rising, and communities are speaking up against risky tar sands oil

projects and in favor of responsible, wildlife friendly clean energy solutions.

LA VACA VEGETARIANA AT FLICKR.COM

To protect wildlife, resources, and communities, we recommend:

➤ The State Department should conduct a thorough public environmental review of the proposed

Alberta Clipper expansion that accounts for all of the risks posed to the Great Lakes region and

beyond from increased tar sands oil transport across the border.

➤ The State Department should consider the comprehensive impact of the multiple tar sands oil

pipelines with permit applications before them, including the Alberta Clipper and Keystone XL.

Taken together, these two lines will have a substantial impact on the industry’s ability to expand

and create more pollution and spill risks.

➤ President Obama should consistently apply his “climate test”15 to all tar sands oil pipelines, and

reject them if they are found to significantly exacerbate the problem of carbon pollution, as he

has committed to doing with Keystone XL.

➤ President Obama should deny the Alberta Clipper expansion because it poses too high a risk to

the people and wildlife of the Great Lakes region, fails his climate test, and is therefore not in

the nation’s best interest.

➤ President Obama should direct his Administration to utilize existing regulatory authority

to require the best technology and safest methods for transporting tar sands oil. The

Administration must update old, industry-friendly pipeline safety and rail regulations that

unnecessarily place wildlife and communities at risk.

➤ States in the Great Lakes region should put in place policies, like Clean Fuel Standards, that

will reduce reliance on dirty fossil fuels and speed the transition to clean, renewable sources of

energy that protect wildlife and people.

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The Great Lakes are among the world’s most valuable

resources. At 95,000 square miles of surface area, the

Great Lakes hold approximately 22% of the planet’s

fresh water, and constitute the world’s largest source of

available fresh water.16 The Great Lakes are a mecca for

outdoor recreation and wildlife enjoyment. From remote shores

where Loons call, Wolves howl, and the Milky Way paints

the night sky, to the busy metropolises of Chicago, Detroit,

and Cleveland where waterfront parks and beaches serve as

oases for outdoor enjoyment, the region provides millions

of Americans with the opportunity to experience wildlife

and nature.

Together, the massive Great Lakes basin makes up “one of the

world’s most remarkable ecosystems”17 containing globally

significant biological diversity that has been described as

“unique in the world.”18 It provides habitat for species from

Bald Eagles to Moose, serves as an immense fishery, and gives

home to a great many threatened and endangered species,

including Lake Sturgeon, the Canada Lynx, the Kirtland’s

Warbler, the Karner Blue Butterfly, and the Indiana Bat.19

The Great Lakes basin “supports more than one-tenth of the

U.S. population and more than one-fourth of the population

of Canada.”20 Approximately 7% of the total U.S. agricultural

production occurs in the basin (nearly 25% for Canada) as

well.21 A critical source of drinking water in the middle of

the continent, the Great Lakes provide drinking water to

approximately 40 million people.22

The Great Lakes RegionA GLOBAL TREASURE UNDER THREAT

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However, this highly important region is under immense threat.

The multiple risks associated with the extraction, transport and

combustion of tar sands oil—one of the dirtiest, high-carbon

fuels on the planet—jeopardizes the Great Lakes region and the

millions of people and countless wildlife species that depend

on the treasured resources of this area.

Tar sands oil is a dirty, carbon-intensive form of crude oil

transported from vast extraction sites in northern Alberta

to the Great Lakes region. Today, tar sands oil is transported

to and through the Great Lakes region via pipeline, rail, and

barge, and could come across the lakes on tankers if tar sands

expansion continues. Ruptures, accidents and spills happen on

all transport options.

Most tar sands oil shipments, however, occur via pipeline.23

Enbridge, a major pipeline company, owns the system of

pipelines that carry tar sands oil from Alberta to and then

through the Great Lakes region. Of these, a line called the

Alberta Clipper functions as the “aorta,” pumping tar sands

across the border into North Dakota to a byzantine array of

pipelines that then carry tar sands through the region and

beyond, increasingly bound for export terminals.

Most tar sands oil is transported as a heavy grade oil known

as diluted bitumen, or “dilbit.” Dilbit is heavy, toxic, and nearly

impossible to clean up.24 Tar sands oil spills could cause

irreparable harm in the Great Lakes region and to the bountiful

wildlife of this wonderful area. Pipelines and rail routes cut

across huge swaths of forested land, rivers, wetlands, lakes and

other bodies of water that wildlife depend upon. At-risk wildlife

includes the majestic Moose in Minnesota’s north woods, the

tiny endangered Illinois Chorus Frog near the Mississippi River

in Illinois, the Trumpeter Swans in Michigan’s Upper Peninsula

and the Whooping Cranes in Wisconsin. The Great Lakes region

cannot afford the risks of tar sands oil.

What is Tar Sands

Tar sands oil spills could cause irreparable harm in the Great Lakes region and to the bountiful wildlife of this wonderful area. Pipelines and rail routes cut across huge swaths of forested land, rivers, wetlands, lakes and other bodies of water that wildlife depend upon.

JANE BECKER

8 | NATIONAL WILDLIFE FEDERATION

Tar sands oil is found in the ground as a mix of tar-like

bitumen and sand. The largest deposit exists in Northern

Alberta.25 Similar to hardened tar in consistency, tar

sands oil is a mixture of sand, clay, water and a semi-solid

form of petroleum formally known as “bitumen” that has little

resemblance to conventional crude oil.

Because it is so

heavy and sticky, tar

sands oil cannot be

pumped out of the

ground in liquid form

like conventional

oil, so producers

must extract it using

energy-intensive

processes. Originally,

most tar sands

oil extraction was

accomplished through open pit mining.26 While surface mining

continues, an even more energy-intensive method called

“in-situ” extraction is now largely employed.27 This involves

drilling a series of horizontal pipelines some 600-700 feet

into the ground and injecting steam to heat up and soften

the bitumen for extraction.28 In addition to using enormous

amounts of energy, this form of drilling fragments and destroys

large tracts of evergreen boreal forest—habitat for countless

North American migratory birds and other wildlife. Overall,

an area the size of Florida is potentially threatened by tar

sands oil development, and many species of birds, mammals

and endangered wildlife like Whooping Crane and Woodland

Caribou are threatened by habitat destruction and the

massive toxic tailings ponds that birds often mistake for safe

landing sites.29

A Carbon Bomb

Tar sands oil is one of the most carbon-intensive forms of oil

on the planet.30 Average greenhouse gas (GHG) emissions from

tar sands oil extraction and upgrading (a pre-refining process)

are an estimated three to five times as intensive per barrel

as emissions from conventional oil.31 Over its full cycle (from

production to transport to refining to transport), tar sands oil

is between 8% and 37% more carbon polluting than regular

crude oil32 due to higher emissions caused by mining, drilling

and separating the bitumen from the sand and clay in which it

is found.33 Estimates by groups evaluating numbers from the

International Energy Agency show that tar sands expansion

plans, if allowed, would greatly exceed carbon pollution levels

scientists have agreed would avert catastrophic climate

change impacts.34

Extreme Spill and Transport Risk

Since it is landlocked in a remote region, getting tar sands

oil to market means transporting it over long distances by

pipeline, rail, ship or barge. This transport creates risks for

wildlife and communities along those routes. Nowhere has this

Oil and Why It Is So Dangerous to People and Wildlife

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been more tragically illustrated than with the disastrous July

2010 spill of roughly one million gallons of tar sands oil into the

Kalamazoo River, the largest inland oil spill in U.S. history. After

pouring into the river, much of the tar sands oil sank to the

bottom, causing widespread contamination, which has proved

nearly impossible to remediate.35

While spills, leaks and ruptures are becoming almost

commonplace in the world of crude oil transport, the risks of

moving tar sands are greater than those associated with the

transport of conventional crude oil. Tar sands oil is so heavy

it must be mixed with toxic diluents to be moved through

pipelines or onto barges,36 and the increased friction from

thick tar sands oil pushing through a pipeline makes it hotter.37

The heat may increase the chances of a pipeline rupture, and

once spilled, the weight of the tar sands oil causes it to sink

when released into bodies of water.38

In addition to pipelines, the tar sands oil industry has also

begun to use other modes of transport. “Crude-by-rail”

for example, while not serving as an economic or scalable

replacement for tar sands oil pipelines, is expanding with

derailments, explosions and spills as the sad result.39 Since

2005, there has been a 70-fold increase in oil rail shipments in

the United States, with approximately 800,000 bpd currently

being shipped.40 Rail is used mainly to move oil from the

Bakken fields in the Dakotas and Montana, but tar sands oil

shipments by rail from Canada to U.S. refineries are on the

rise. Tar sands oil is now also being transported long distances

across inland waterways by barge. While thus far companies

have only transported tar sands oil by barge via rivers, such

as the Mississippi,41 signs suggest the Great Lakes are next.42

That could mean ships as well as barges. A barge spill on the

Great Lakes would be catastrophic, with oil potentially coating

habitat and shorelines for miles.

Pollution and “Petcoke” at Refineries

Refining tar sands oil to produce fuels like gasoline and diesel

causes serious air pollution problems for local communities

and wildlife. In addition to producing toxic air emissions,

refineries located on rivers and lakes pose spill risks to fresh

water, which is what happened at the BP Whiting, Indiana

refinery. This refinery spilled roughly 1,200 gallons of crude

oil, likely tar sands, into Lake Michigan in March 2014.43

Fortunately, this spill was relatively small and appears to have

been contained, but it serves as a warning of the dangers of

refining tar sands on the banks of the Great Lakes.

Refining heavy grade tar sands oil also creates a solid

byproduct similar to coal but with even higher carbon

emissions, known as petroleum coke or “petcoke.”44 Heaps of

this dusty, polluting substance are now piling up near refineries

in places like Chicago and Detroit. These piles often sit

adjacent to communities, whose residents are often no longer

able to keep their windows open given the high level of dust in

the air.

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What’s at Risk for People and Wildlife in the Great Lakes Region if a Tar Sands Pipeline Spills?

 

 

 

 

 

 

 

 

 

 

 

 IN MINNESOTA… IN WISCONSIN… IN ILLINOIS…

PIPELINES

Southern Access Pipeline (Line 61)

Line 6A (feeds Line 6B)

new Wisconsin-Illinois pipeline

(not yet announced)

SPECIAL PLACES

6. Chequamegon-Nicolet National Forest

7. Necedah National Wildlife Refuge

4. St. Louis River Estuary

5. Lake Superior

8. Lake Michigan

9. Brule River State Forest

SPECIES THREATENED OR AT RISK

Karner Blue Butterfly, Whooping Crane, Piping Plover, Kirtland’s Warbler, Red-Necked Grebe, Common Goldeneye, Black Tern, Rufa Red Knot, Long-eared Owl, Blanding’s Turtle, Canada Lynx

PIPELINES

Southern Access Pipeline (Line 61)

Southern Access Extension

Line 6A (feeds Line 6B)

Flanagan South, Line 62

Line 78

Eastern Gulf Crude Access Pipeline

new Wisconsin-Illinois pipeline (not yet announced)

SPECIAL PLACES

8. Lake Michigan

10. Coastal gems in the Chicago area such as Lincoln Park/Montrose Bird Sanctuary and Chicago’s 26 miles of beaches

11. Illinois River

12. Midewin National Tallgrass Prairie

13. Mississippi River

SPECIES THREATENED OR AT RISK

Spotted Turtle, Ornate Box Turtle, Illinois Chorus Frog, Cerulean Warbler, Wood Duck, Barn Owl, Loggerhead Shrike, Least Bittern, Upland Sandpiper, Wilson’s Phalarope, Osprey, rare Freshwater Mussels, Lake Sturgeon

PIPELINES

Alberta Clipper, Line 3

SPECIAL PLACES

1. Chippewa National Forest

2. Agassiz National Wildlife Refuge

3. Itasca State Park (headwaters of the Mississippi River)

4. Saint Louis River Estuary

5. Lake Superior

SPECIES THREATENED OR AT RISK

Moose, Canada Lynx, Wood Turtle, Hooded Warbler, Horned Grebe, Trumpeter Swan, Burrowing Owl, Peregrine Falcon, Red-shouldered Hawk, American White Pelican, Sprague’s Pipit, Henslow’s Sparrow, Baird’s Sparrow, Lake Sturgeon

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TREASURED HABITAT AREAS

➤ Chippewa National Forest, northern Minnesota:

The Alberta Clipper and other Enbridge pipelines

cross parts of this 1.6 million-acre forest,51 home to

the highest breeding population of Bald Eagles in the

lower 48 United States.52 The forest also provides

habitat for Osprey, Eagles, Pileated Woodpeckers,

Hawks, Red Foxes and White Tail Deer,53 and contains

eight different types of wetlands, each with distinct

plant and animal life.54

➤ Saint Louis River Estuary, at the Duluth-Superior

port on Lake Superior: This highly prized 12,000-

acre freshwater estuary is representative of the

unique biodiversity of the Great Lakes region.55 The

Alberta Clipper’s expansion would put the estuary at

great risk given its close proximity. The estuary “is

critical to the life-cycle of millions of fish, waterfowl,

raptors and song birds in the Lake Superior region”56

and is part of the National Estuarine Research

Reserve System.57

➤ Brule River State Forest, Wisconsin: This forest,

adjacent to Line 61, encompasses all 44 miles of

the Bois Brule River, a renowned trout stream for

over one hundred years, containing native brook,

brown and rainbow trout.58 Lake Brown and Rainbow

(Steelhead) Trout and Coho and Chinook Salmon

make their annual migration up the Brule from

Lake Superior.59

➤ Necedah National Wildlife Refuge, Wisconsin: This

refuge takes the lead in the recovery and restoration

of the Whooping Crane60 and is located next to

Line 61 and the other Enbridge pipelines running

diagonally across the state. The Whooping Crane

was brought back from the brink of extinction and is

currently on the trail of recovery, representing a true

symbol of hope for endangered species.61 Tar sands

oil expansion would put this phenomenal progress in

jeopardy by destroying breeding habitat in Alberta,

creating hazardous tailing ponds near extraction

sites, and posing risks such as pipeline spills along

migrations routes.

DRINKING WATER SUPPLIES

➤ Duluth, Minnesota depends on Lake Superior for its

drinking water,45 and is located next door to Superior,

WI, where the Alberta Clipper pipeline pumps tar

sands oil to connecting pipelines and supplies the

refinery on Lake Superior’s shores.

➤ Chicago, Illinois and suburbs rely on Lake Michigan

to supply drinking water to some 7 million people,46

living at the edge of a complex tangle of tar sands

oil pipelines and feeding area refineries like the BP

refinery at Whiting, IN. Lake Michigan is the largest

public drinking water supply in the State of Illinois,

serving nearly 8.5 million people (of a total of over 10

million lake-wide).47

➤ Gary, Indiana, the state’s ninth largest city, also taps

Lake Michigan. A spill at or near BP’s Whiting refinery

could devastate Gary’s water supply.48

➤ Milwaukee, Wisconsin’s largest city, also relies

on Lake Michigan49 and is at risk of spills from Line

61 and other tar sands pipelines passing between

it and Madison en route to Chicago area refineries

and beyond.

➤ Toledo, Ohio relies on Lake Erie for its drinking

water,50 but is also home to the BP-Husky Toledo

Refinery, fed by Enbridge’s Line 17 tar sands

oil pipeline.

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Climate Change Impacts in the

Great Lakes RegionTODAY AND TOMORROW

Given its high life cycle

carbon emissions, tar

sands oil exacerbates

climate change. As was just

seen in the Toledo, Ohio

drinking water crisis, the

Great Lakes region has much

to lose if climate change

goes unchecked under a

“business as usual” scenario

with planned tar sands oil

expansion. The 2014 National

Climate Assessment,62 paints

a disturbing picture of such

impacts. The special and

irreplaceable ecosystems of

the Great Lakes region are

likely to suffer greatly if we do

not stem the tide of climate

change. Many impacts have

already arrived and will only

worsen if we do not take action

to reduce climate-changing

carbon pollution.

➤ Toxic Algal Blooms. Toxic

algal blooms are on the rise

as waters warm and storms

The dangers of toxic algal blooms have already reached crisis levels in the Great Lakes

region. This was shown this summer when drinking water supplies were cut off for half a

million residents of Toledo, Ohio when an algal bloom turned the drinking water toxic.63 Lake

Erie—once a shining example of a lake returned to health—is now suffering from some of the

worst algal blooms in its history with decades of clean-up efforts increasingly thwarted by

climate-driven extreme weather and associated increases in runoff of agricultural pollution.

A 2011 algal bloom caused an estimated $2.4 million dollar loss in Ohio’s recreational

fishing industry and could easily be seen from space, as roughly a sixth of the lake’s

surface was pea green.64 Climate change feeds algal blooms by creating the conditions in

which cyanobacteria—which is also called blue green algae—thrives. Dry periods followed

by intense rain events—something that will increase with climate change—cause nutrients

from agriculture and urban development to be flushed at higher rates into nearby waters.

These nutrients, along with higher temperatures, feed cyanobacteria and make algal blooms

larger, more frequent, and more toxic.65

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worsen, providing conditions ripe for blue-green algae

to flourish, choking and poisoning the lakes. This creates

massive dead zones for fish and wildlife, turning water into

a toxic, smelly, pea soup that is not only perilous to wildlife,

but also unpleasant and even dangerous for outdoor

recreation. It can also be devastating to drinking water

supplies.

➤ Reduced Ice Coverage. Despite last winter’s high ice

coverage, ice coverage on the Great Lakes is trending down

substantially from historical levels, making shorelines more

vulnerable to floods and erosion, which in turn causes

nutrient pollution that feeds algal blooms.66

➤ Heavier Rains. Midwest precipitation has increased 37%

since 1958, with more increases expected.67 There has been

more flooding in the region due to the sudden and heavy

downpour variety of precipitation associated with climate

change. This has increased sediment and nutrient loading,

feeding toxic algal blooms and destroying fish and wildlife

habitat areas.

➤ Drought in dry regions. While the plains region of the

Midwest is not nearly as dry as the drought-stricken

Southwest, it too is at risk to become dryer as climate

change accelerates. The heavier rains mentioned above will

not, unfortunately, reach the dry regions on a regular basis,

and when they do, they will be too intense to be helpful

when parched ground is unable to absorb massive amounts

of sudden rainfall.

➤ There has been more flooding in the region, and lower

crop yields as warming increases. Despite the possibility

of longer growing seasons for some crops, unstable weather

will cause things like unpredictable frosts and thaws at the

wrong time, wreaking havoc on agricultural cycles. Droughts

like the record-breaker in the Midwest in 201268 may also

become more frequent.

➤ Extreme heat in summer. While the polar vortex made

this year relatively cool in the Great Lakes region, the clear

trend towards higher air temperatures will trigger a whole

set of serious problems involving increased air pollution and

ozone problems aggravated by heat waves. Worsened air

quality means less healthy air for wildlife and people who

seek to enjoy the outdoors.

All of these impacts of climate change will be exacerbated by a

shift to higher-carbon sources of fuel, like tar sands oil.

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The Kalamazoo River Calamity

Sadly, the Great Lakes region has already suffered a

horrific example of what can happen when tar sands

oil pipelines fail. The tar sands oil pipeline spill into

Michigan’s Kalamazoo River in July 2010 showed

what happens when heavy tar sands oil spills in a

marsh, stream or river: an environmental catastrophe

occurs that cannot be reversed.69 Now well-known by

citizens and environmentalists around the country, the

spill happened when Enbridge Line 6B (operated by

Enbridge Energy Partners) split open near Marshall,

Michigan and more than one million gallons of tar

sands oil gushed out through a six-and-a-half-foot

gash in the pipeline. The spill ultimately contaminated

roughly 40 miles of the Kalamazoo River. It also caused

families and businesses to evacuate, and many of those

who evacuated reported a host of medical problems,

from headaches to vomiting to rashes.70

The Enbridge tar sands oil spill at Kalamazoo was the

largest inland oil pipeline spill in U.S. history.71 Cleanup

has cost Enbridge an estimated $1 billion72 and a key

reason for the incident’s high cost is that the substance

spilled was tar sands oil. It coated marsh grasses,

Great Blue Herons, turtles and other wildlife. About

one-quarter of the birds died and the fate of small

mammals, like Beavers, was even worse: nearly 63.5%

died.73 What didn’t coat flora and fauna above the

water, sank to the bottom. Officials evaluating impacts

one year after the spill worried that the spill had

harmed fish eggs and the main diet for fish, tiny midges

and flies.74

The National Transportation Safety Board (NTSB)

investigation75 concluded that the rupture was most

likely caused by “corrosion fatigue cracks that grew

and coalesced from crack and corrosion defects,”

The six-and-a-half foot rupture in Enbridge Line 6B: over one million gallons of tar sands oil gushed into the Kalamazoo River.

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14 | NATIONAL WILDLIFE FEDERATION

which in turn produced a spill “that went undetected

by the control center for over 17 hours.” In evaluating

Enbridge’s handling of the spill, the NTSB found that

the rupture and prolonged release were made possible

by “pervasive organizational failures at Enbridge

Incorporated.”76 When it announced the result of

the investigation, the NTSB blamed Enbridge for a

“complete breakdown of safety” in relation to the

response to the spill.77 Human error, combined with

hard-to-detect leaks,78 makes tar sands pipeline spills a

question of when, not if.

Enbridge’s overall track record on spills is consistent

with the NTSB’s assessment of their failure during the

Kalamazoo spill. According to Enbridge’s own reports,

the company has been responsible for 1,100 pipeline

spills over the last 15 years (1999-2013).79 Together,

these Enbridge spills amounted to approximately

7.5 million gallons of oil-related products, over

two-thirds of the amount of oil spilled by the Exxon

Valdez (11 million).

The spill, which originated in a nearby marsh, shows

how complicated responding to remote area spills can

be.80 Enbridge had to build a 1/4-mile-long road of wood

mats, just to access the site. Responders feared that

if it rained, booms placed in a nearby creek might not

prevent contamination of the upper Mississippi River,

and so opted for a controlled burn (photo above, left).

The resulting smoke plume one mile high and five miles

long (photo above, right).

Kalamazoo is not the only major tar sands oil spill in the

industry’s relative short history of bringing tar sands oil

through pipelines in the United States. In March of 2013,

the ExxonMobil-owned Pegasus Pipeline burst, sending

tar sands oil gushing through the streets of a quiet,

residential neighborhood not far from the Arkansas

capital of Little Rock. Before it burst, the 65-year-old

pipeline carried 95,000 barrels per day of tar sands

crude from Patoka, Illinois to Nederland, Texas crossing

a large piece of southwestern Illinois.81 Like many

pipelines, it traversed numerous neighborhoods, farms

and waterways. As in Marshall, Michigan, people living

near the tar sands spill site experienced multiple health

issues, and increased levels of benzene were found in

the air following the spill.82

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Tar sands crude gushes between homes following a tar sands spill in Mayf lower, Arkansas in 2013. The pipe-line originates in Illinois.

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NATIONAL WILDLIFE FEDERATION | 15

A controlled burn to limit the spread of a crude oil spill from an Enbridge pipeline in Cohasset, MN in 2002.

16 | NATIONAL WILDLIFE FEDERATION

The primary reason the tar sands oil industry needs these

pipelines is to export their product overseas. To date, the

Canadian tar sands oil industry’s biggest customer has

been the United States.83 However, thanks in part to effective

policies from the Obama Administration that have helped

improve vehicle efficiency and reduce our oil consumption,

U.S. demand is dropping.84 This, along with increased oil

production within the U.S.,85 leaves the tar sands oil industry

looking for new markets for their product. This is why tar

sands oil producers are interested in moving their product to

coastal, export-oriented markets where demand, crude prices,

and profits are higher, so they can sell to oil-hungry countries

abroad that will pay top dollar.

As a result, where most tar sands previously traveled from

Canada to the Great Lakes region, it may also soon travel

through the Great Lakes region. Using the Great Lakes region

as shortcut to world markets and higher profits is a move that

threatens the region’s communities, wildlife and habitat.

Tar Sands Oil Pathways to—and Through— the Great Lakes Region

Once tar sands oil is extracted, it leaves Alberta and heads

towards the U.S. border on a large trunk of Enbridge pipelines

known in Canada as the “Mainline”86 and in the U.S. as the

“Lakehead system.”87 Enbridge boasts that it owns and

operates the largest system of crude oil pipelines in the

world,88 with over 15,000 miles of pipeline already transporting

Big Oil’s Bid to Export Harmful Tar Sands through the Great Lakes Region

crude oil to or through the U.S.89 At the town of Neche, North

Dakota, just a few miles from Minnesota’s northwest corner,

Enbridge’s main pipelines cross the U.S./Canadian border.

From there, the bundle of pipelines that make up the Lakehead

system head southeast through the wildlife rich forests of

Northern Minnesota toward the Great Lakes region. The

primary arterial lines run southeast in parallel to Superior,

Wisconsin, where they then broadly branch out to supply crude

oil to U.S. refineries and coastal ports.

Alberta Clipper: Linchpin of Enbridge Expansion Plans

Of the various Enbridge pipelines that carry tar sands from

Alberta to the U.S., the Alberta Clipper is the largest dedicated

trans-boundary tar sands oil line, and the key to expanding the

tar sands oil industry’s export potential out of Canada.90 Also

referred to as Line 67, the Alberta Clipper takes tar sands oil

over 1000 miles from Hardisty, Alberta to Superior, Wisconsin

near the shores of the largest of the Great Lakes, Lake

Superior, not far from Duluth, Minnesota.

Tar sands oil is delivered to Superior , Wisconsin, for refining

at the Calumet Specialty Products Partners Refinery, which,

like 90% of the refineries in the Great Lakes bi-national region,

processes tar sands oil.91 Tar sands oil flowing on the Alberta

Clipper is also transferred to other pipelines headed for the

Gulf Coast and Central-Eastern Canada. These pipelines run

throughout the region, cutting across streams, wetlands and

CATHERINE HENNESSEY/NWF PHOTO CONTEST

NATIONAL WILDLIFE FEDERATION | 17

EXISTING AND… …PROPOSED LINES

ENBRIDGE PIPELINES

SHOWN BELOW CLICK HERE

 

 

 

 

Lines 1, 2, 4, & 65

Combined 1,660 kbpd

Superior Refinery

Line 5491 kbpd

Sarnia RefineriesImperial . . . . .121 kbpdShell . . . . . . . . 71 kbpdSunoco . . . . . .85 kbpdNova . . . . . . . 80 kbpd

Line 7150 kbpd

Nanticoke Refinery112 kbpd

Montreal RefinerySuncor

137 kbpd

Quebec City RefineryValero

235 kbpd

Tanker Shipments

New Sandpiper 365 kbpd

Tanker Shipments

Line 6a 667 kbpd Line 14/64

318 kbpd

Line 62 150 kbpd

Line 17101

kbpd

Line 79 80 kbpd

Sunoco 190 kbpd

Line 11 117 kbpd

Kiantone70 kbpd

Line 10 74

kbpd

United Refinery70 kbpd

Chicago Area RefineriesBP . . . . . . . . . . . 413 kbpdExxon Mobil . . . 250 kbpdPVD . . . . . . . . . . 180 kbpd

MI & OH RefineriesDETROIT

Marathon . . . . . 102 kbpdTOLEDO

BP Husky. . . . . . 160 kbpdPBF . . . . . . . . . . 140 kbpd

KEY

Possible Expansions

Public Expansions

No Change

Oil Refinery

Oil Terminal

kbpd Thousand barrels per day

     

 

NATIONAL WILDLIFE FEDERATION | 1818 | NATIONAL WILDLIFE FEDERATION

 

 

 

 

NEW Line 3 760 kbpd

Replaced and Expanded

Superior Refinery

Sarnia RefineriesImperial . . . . .121 kbpdShell . . . . . . . . 71 kbpdSunoco . . . . . .85 kbpdNova . . . . . . . 80 kbpd

Nanticoke Refinery112 kbpd

Line 9 300 kbpd

Reversal and Expansion

Montreal RefinerySuncor

137 kbpd

Quebec City RefineryValero

235 kbpd

Tanker Shipments

New Sandpiper 365 kbpd

Alberta Clipper(Line 67) 450 bpd

Expanded to 800 kbpd

Line 61400 bpd

Expanded to 1,200 kbpd

Flanagan South/Seaway to Gulf

800 kbpd

New Line 66Est. 800

kbpd

New Southern Access

Extension365 kbpd

Tanker Shipments

Possible Capline

Reversal 1,200 kbpd

NEW Line 78

800 kbpd

Line 62 150 kbpd

Line 6bExpanded to

800 kbpd

United Refinery70 kbpd

PMPL 18”190 kbpd (Reversal)

PMPL 24”410 kbpd (Reversal)

Chicago Area RefineriesBP . . . . . . . . . . . 413 kbpdExxon Mobil . . . 250 kbpdPVD . . . . . . . . . . 180 kbpd

MI & OH RefineriesDETROIT

Marathon . . . . . 102 kbpdTOLEDO

BP Husky. . . . . . 160 kbpdPBF . . . . . . . . . . 140 kbpd

KEY

Possible Expansions

Public Expansions

No Change

Oil Refinery

Oil Terminal

kbpd Thousand barrels per day

     

 

EXISTING AND… …PROPOSED LINES

ENBRIDGE PIPELINES

CLICK HERE SHOWN BELOW

Lines 1, 2, 4, & 65

Combined 1,660 kbpd

Line 5491 kbpd

Line 7150 kbpd

Line 6a 667 kbpd Line 14/64

318 kbpd

Line 79 80 kbpd

Line 17101

kbpd

Sunoco 190 kbpd

Line 11 117 kbpd

Kiantone70 kbpd

Line 10 74

kbpd

NATIONAL WILDLIFE FEDERATION | 19

rivers that flow into the Great Lakes. These lines include Line

6B—the line whose rupture caused the horrific Kalamazoo

River disaster in July of 2010. The vast pipeline network feeds

multiple refineries throughout the region, primarily in larger

urban areas like Chicago and Detroit. Industry is increasingly

seeking new routes south and east to access export markets

available from the Gulf Coast and East Coast.

The Alberta Clipper feeds this entire network and92 its

expansion is sought for increasing tar sands oil into the

Great Lakes region. Enbridge is currently seeking to expand

the Alberta Clipper’s capacity from 450,000 bpd to as much

as 800,000 bpd by constructing new pumping stations and

making other modifications.93 The proposed expansion is

to take place in two phases. The Minnesota Public Utilities

Commission has already approved the upgrades.94

This expansion needs to be considered under a public

environmental review process and national interest

determination by the President, a process started last year

by the Department of State, which has primary permitting

authority. However, the State Department has acquiesced

to a scheme from Enbridge that would allow this expansion

to occur via a supposedly temporary diversion of tar sands

oil from the Alberta Clipper to parallel Line 3 at the border

crossing.95 Line 3 is an aging pipeline that sits next to the

Alberta Clipper and has historically carried conventional oil.

While Line 3 has not been used for heavy tar sands oil at a high

capacity, Enbridge is arguing that the lack of an express limit

on that Line’s capacity makes the scheme permissible.

However, the scheme is contrary to the permit Enbridge

currently holds that limits tar sands oil capacity to 450,000

bpd on the Alberta Clipper,96 violates Federal Law requirements

of an environmental review and a national interest

determination, and undermines the ongoing public review

process.97 It is critical that the State Department reverse this

decision and ensures that no tar sands oil expansion of the

Alberta Clipper will proceed without the proper legal process.98

Ultimately, the Presidential Permit should be denied because

this proposed expansion places the Great Lakes region at

unneeded and unacceptable risk.

GEORGE GENTRY/U.S. FISH AND WILDLIFE SERVICE

20 | NATIONAL WILDLIFE FEDERATION

The list below shows the primary pipeline expansions

Enbridge could use to carry tar sands through the Great

Lakes region and to distant export markets if the Alberta

Clipper is expanded along with other pipelines in Enbridge’s

Lakehead system crossing from Canada into the U.S.

EXPANSION Southern Access Pipeline (Line 61): This

Enbridge pipeline from Superior, WI to Flanagan, IL is one of

the widest pipelines in the system, 42-inches in diameter. It

can carry large volumes of tar sands and would function as

a critical link between the Alberta Clipper and a new pipeline

Enbridge would like to build in its rush to the Gulf Coast,

Flanagan South (described below). Line 61’s expansion is slated

to happen in two phases, which together would boost pipeline

capacity from 400,000 to 1.2 million bpd. Only an initial part of

the project has gone forward, involving a capacity increase to

560,000 bpd expected to be in operation by Fall 2014.99

NEW Southern Access Extension (aka SAX): This new

300,000 bpd Enbridge pipeline proposed to run from

Flanagan, IL to Patoka, IL would extend the reach of Line

61.100 Its relatively small length and size relative to other

components in Enbridge’s expansion plans is deceiving: SAX

provides a key link that is enabling yet another massive north-

to-south pipeline (See “Eastern Gulf Crude Access Pipeline,”

below). It has yet to receive regulatory and other approvals.

NEW Flanagan South: Also entirely new, this Enbridge

project will run a 36-inch pipeline from Flanagan IL to Cushing

OK, closely paralleling the existing Enbridge Spearhead

pipeline. While it’s starting capacity would be 585,000 bpd

that could be increased to 800,000 bpd—nearly the capacity of

Keystone XL.101 The National Wildlife Federation and the Sierra

Club have taken legal action to stop further progress of the

pipeline, but received a decision that no comprehensive review

is needed.102 This decision has been appealed. Yet, construction

is nearing completion, and the pipeline is slated to be in service

by the end of 2014.103

EXPANSION Eastern Gulf Crude Access Pipeline (EGCAP

or “Trunkline Conversion”): While not an Enbridge project

per se, the EGCAP project is closely tied to Enbridge’s plan to

push more Canadian tar sands to the Gulf. Proposed by Energy

Transfer Partners (ETP), the pipeline would convert a natural

gas pipeline to crude oil, and reverse its direction104 to run

south from Patoka IL to Boyce LA.105 If completed, the 420,000

bpd EGCAP project would create the first “express route”

from the Midwest (Patoka, IL) to the refineries of Louisiana.106

The Alberta Clipper and other Enbridge expansions to the

north would make it possible: EGCAP would connect in the

north, at Pakota, with the Southern Access Extension (SAX),

linking EGCAP directly to Line 61 in Enbridge’s massive

Lakehead system.107

EXPANSION Line 6B: In 2013 and early 2014, Enbridge

replaced some 75 miles of Line 6B, the pipeline that caused

the Kalamazoo tar sands spill of 2010. Additional replacements

are planned in both Indiana and Michigan, and in conjunction

with new pumps and other upgrades, capacity will be increased

Riding the Coat Tails of the Alberta ClipperYET MORE PLANNED PIPELINE EXTENSIONS

ANDYTALLEY

NATIONAL WILDLIFE FEDERATION | 21

from 240,000 to 500,000 bpd.108 Enbridge is also planning

an additional capacity boost from 500,000 to 570,000 bpd.109

The expansion of Line 6B is especially concerning in light of

the Line’s recent history, Enbridge’s publicly denigrated safety

record, and the huge harms already suffered by people and

wildlife along the line.

EXPANSION Line 62/NEW Line 78: Line 62, also called

Spearhead North, is a short pipeline connecting Flanagan IL

to Griffith IN. Line 61 feeds it from the north. The expansion

of Line 62 was completed in 2013 and increased the line’s

capacity from 130,000 to 235,000 bpd. Enbridge plans to also

build a new line, Line 78, which would parallel Line 62 for most

of its route and run north from Enbridge’s Flanagan terminal

near Pontiac, IL to Griffith, IN. This new pipeline, also known

as the Spearhead North Twin, would have an initial capacity of

570,000 bpd.110

EXPANSION Line 3: The modifications planned for Line 3,

which runs from Hardisty, AB to Superior, WI, are some of

the largest Enbridge expansions planned for the Great Lakes

region. Billed by Enbridge as a pipe replacement project, this

is an expansion in disguise. According to Enbridge, the project

will let Line 3 reach an “equivalent capacity of 760,000 bpd”111

compared to its current capacity of 390,000 bpd. The U.S.

segment would be replaced with new, larger pipe in most

areas. To carry tar sands on Line 3 would constitute change

from previous use, and thus a Presidential Permit and new

environmental and safety reviews should be required.112 As

described above, Enbridge has already signaled its intentions

to push tar sands through a segment of Line 3 that crosses the

U.S.-Canada border.

NEW Wisconsin-Illinois Pipeline: While not yet formally

announced or given a project name, there are signs that

Enbridge is planning to build yet another pipeline in the region.

Landowners along current Enbridge Line 61, which cuts across

Wisconsin into northern Illinois, received notices in early 2014

indicating that the company would be conducting survey

activities in relation to a “potential expansion of its pipeline

system in Wisconsin and Illinois.”113

JOHN J. MOSESSO, NBII

22 | NATIONAL WILDLIFE FEDERATION

➤ The State Department should consider the comprehensive

impact of the multiple tar sands oil pipelines with permit

applications before them, including the Alberta Clipper and

Keystone XL. Taken together, these two lines will have a

substantial impact on the industry’s ability to expand and

create more pollution and spill risks.

➤President Obama should consistently apply his “climate

test”114 to all tar sands oil pipelines, and reject them if they

are found to significantly exacerbate the problem of carbon

pollution, as he has committed to doing with Keystone XL.

➤ President Obama should deny the Alberta Clipper expansion

because it poses too high a risk to the people and wildlife of

the Great Lakes, fails his climate test, and is therefore not in

the nation’s best interest.

➤ President Obama should direct his Administration to utilize

existing regulatory authority to require the best technology

and safest methods for transporting tar sands oil. The

Administration must update old, industry-friendly pipeline

safety and rail regulations that unnecessarily place wildlife

and communities at risk.

➤ States in the Great Lakes region should put in place policies,

like Clean Fuels Standards, that will reduce reliance on dirty

fossil fuels and speed the transition to clean, renewable

sources of energy that protect wildlife and people.

Taking Action

Tar sands oil poses unacceptable risks to the Great

Lakes region’s treasures of wildlife, communities and

outdoor enjoyment. We do not have to accept those

risks. Rather than building dangerous infrastructure that

places our largest freshwater resources at risk, we need to

invest in clean, wildlife-friendly energy sources and expand

clean transportation solutions. The climate crisis requires

serious efforts in the reduction of carbon pollution and further

transition from dirty fossil fuels to clean energy resources

such as, geothermal, on and offshore wind, solar, sustainable

bioenergy, and efficient transportation technologies. We can

make changes to reduce our energy use and simultaneously

lower our energy bills. We can make changes that connect us

to one another and our communities. We can create more open

space for wildlife and recreation to be enjoyed for generations

to come. We can build an energy future that promotes and

protects wildlife, communities and the many treasures of the

Great Lakes, rather than continuing to put these resources in

harm’s way.

To protect wildlife, resources, and communities, we

recommend:

➤ The State Department should conduct a thorough public

environmental review of the proposed Alberta Clipper

expansion that accounts for all of the risks posed to the

Great Lakes region and beyond from increased tar sands oil

transport across the border.

MANJITH KAINICKARA - FLICKR

NATIONAL WILDLIFE FEDERATION | 23

Endnotes1. EPA (U.S. Environmental Protection Agency). June 26, 2012. Great

Lakes Monitoring—Where Would We Be Without the Great Lakes. U,S, Environmental Protection Agency, Washington, D.C. URL: ,http://www.epa.gov/glnpo/monitoring/great_minds_great_lakes/social_studies/without.html (accessed August 15, 2014).

2. EPA. September 25, 2013. Great Lakes Ecosystems. U.S. Environmental Protection Agency, Washington, D.C. URL: http://www.epa.gov/ecopage/glbd/issues/intro.html (accessed August 4, 2014). (Butterfly and Lake Sturgeon)

3. For a general description of the process and impacts of tar sands extraction, see e.g., Kunzing, R. March 2009. The Canadian Oil Boom.,National Geographic. URL: http://ngm.nationalgeographic.com/2009/03/canadian-oil-sands/kunzig-text/1 (accessed August 4, 2014); For facts related to end-uses for tar sands, see e.g., Lattanzio, R. March 10, 2014.Canadian Oil Sands: Life-Cycle Assessments of Greenhouse Gas Emissions. U.S. Congressional Research Service, Washington, D.C.:3. URL: http://fas.org/sgp/crs/misc/R42537.pdf (accessed August 4, 2014).

4. EPA, , July 14, 2014. EPA Response to Enbridge Spill in Michigan. . U.S. Environmental Protection Agency, Washington, D.C. URL: http://www.epa.gov/enbridgespill/ (accessed August 6, 2014).

5. National Wildlife Federation. Growth of Tar Sands Across Midwest. URL: http://www.nwf.org/What-We-Do/Energy-and-Climate/Drilling-and-Mining/Tar-Sands/Michigan-Oil-Spill.aspx (accessed November 4, 2014).

6. Jake Edmiston and Andrew Barr, Mike Faille, Jonathan Rivait, Richard Johnson. August 7, 2014. The Lac-Mégantic Railway Disaster—The Night a Train Destroyed a Town. National Post. URL: http://news.nationalpost.com/2013/07/12/graphic-the-lac-megantic-runaway-train-disaster/ (accessed September 10, 2014).

7. Natural Resources Defense Council. November 2010. Setting the Record Straight: Lifecycle Emissions of Tar Sands. URL: http://docs.nrdc.org/energy/files/ene_10110501a.pdf (accessed September 6, 2014).

8. National Wildlife Federation. Global Warming and the Great Lakes. URL: http://www.nwf.org/Wildlife/Threats-to-Wildlife/Global-Warming/Effects-on-Wildlife-and-Habitat/Great-Lakes.aspx (accessed September 10, 2014).

9. NOAA (National Oceanic and Atmospheric Administration). September 3, 2014. What Is A Dead Zone? URL:. http://oceanservice.noaa.gov/facts/deadzone.html (accessed September 14, 2014).

10. Seville, L. November 8, 2013. Illinois AG and neighbors sue over humongous heaps of ‘petcoke.’ NBC News. URL: http://www.nbcnews.com/news/other/illinois-ag-neighbors-sue-over-humongous-heaps-petcoke-f8C11566275 (accessed September 1, 2014).

11. Enbridge. 2014. Alberta Clipper—Line 67 Capacity Expansion Phase II. URL: http://www.enbridge.com/MainlineEnhancementProgram/Canada/Alberta-Clipper-Capacity-Expansion-Phase-II.aspx (accessed October 6, 2014).

12. Jim Snyder, Rebecca Penty. August 24, 2014. Enbridge Avoids U.S. Review With Plan to Boost Oil Sands, Bloomberg. URL: http://www.bloomberg.com/news/2014-08-21/enbridge-avoids-u-s-review-with-plan-to-boost-oil-sands.html (accessed September 5, 2014).

13. Ibid.

14. Murphy, J. August 25, 2014. State Department Approves Illegal Scheme for Doubling Tar Sands Flowing Through the Great Lakes. National Wildlife Federation. Washington, D.C. URL: http://blog.nwf.org/2014/08/state-department-approves-illegal-scheme-for-doubling-tar-sands-flowing-through-the-great-lakes/ (accessed September 2, 2014).

15. The White House. June 25, 2013, 1:45 P.M. Remarks by President on Climate Change, Georgetown University. Office of the Press Secretary, Washington, D.C. URL: http://www.whitehouse.gov/the-press-office/2013/06/25/remarks-president-climate-change (accessed November 7, 2014).

16. Illinois Environmental Protection Agency. Lake Michigan Monitoring Program. URL: http://www.epa.state.il.us/water/surface-water/lake-michigan-mon.html (accessed October 17, 2014).

17. EPA. Last updated September 25, 2013. Conservation of Biological Diversity in the Great Lakes Basin Ecosystem: Issues and Opportunities. U.S. Environmental Protection Agency, Washington, D.C. URL: http://www.epa.gov/greatlakes/ecopage/glbd/issues/intro.html (accessed September 6, 2014).

18. Ibid.

19. Ibid.

20. Ibid.

21. Ibid.

22. NOAA. About our Great Lakes: Great Lakes Basin Facts. URL: http://www.glerl.noaa.gov/pr/ourlakes/facts.html (accessed September 9, 2014).

23. U.S. Energy Information Administration. 2013. Refinery receipts of crude by method of transportation.U.S.: URL: http://www.eia.gov/dnav/pet/pet_pnp_caprec_dcu_nus_a.htm (accessed September 9, 2014).; Midwest: http://www.eia.gov/dnav/pet/pet_pnp_caprec_dcu_r20_a.htm (accessed September 9, 2014).

24. Song, L. June 26, 2012. A Dilbit Primer: How It’s Different From Conventional Oil. Inside Climate News. URL: http://insideclimatenews.org/news/20120626/dilbit-primer-diluted-bitumen-conventional-oil-tar-sands-Alberta-Kalamazoo-Keystone-XL-Enbridge (accessed November 4, 2014).

25. The oil industry currently uses the term “oil sands”, but as even a well-read industry blog admits, this was a marketing move employed after the original term, “tar sands” was found to have negative connotations. Braziel, R. March 9 2012. It’s a Bitumen Oil….RBN Energy. URL: https://rbnenergy.com/Its-a-bitumen-oil-Does-it-go-too-far-Canadian-oil-sands-crude (accessed September 9, 2014).

26. National Wildlife Federation. May 2014. Migratory Birds and Tar Sands: 5. URL: http://www.nwf.org/~/media/PDFs/Global-Warming/2014/nwf_issue_briefs_Interactive2.pdf (accessed November 4, 2014).

27. The eight tar sands mines currently operating and under active development are: CNRL Horizon, Suncor Fort Hills, Imperial/Exxon Kearl, Shell Muskeg River, Shell Jackpine, Suncor, Syncrude, and Total Joslyn North. Mike Priaro. March 5, 2014. We Are The Champions—Could Alberta’s Oil Sands Reserves Be The Largest on Earth?. RBN Energy. URL: https://rbnenergy.com/we-are-the-champions-could-alberta-s-oil-sands-reserves-be-the-largest-on-earth (accessed September 8, 2014).

28. ISAACS, E. E. 2005. Canadian Oil Sands: Development and Future Outlook. IV International Workshop on Oil and Gas Depletion: ASPO. URL: http://www.cge.uevora.pt/aspo2005/ASPO2005_Proceedings.pdf (accessed November 7, 2014). See also: NEB-EMA. 2006. Canada’s Oil Sands: Opportunities and Challenges to 2015: An update. Calgary, AB, National Energy Board—Energy Market Assessment (NEB-EMA). URL: https://www.neb-one.gc.ca/nrg/sttstc/crdlndptrlmprdct/rprt/archive/pprtntsndchllngs20152006/pprtntsndchllngs20152006-eng.pdf (accessed November 7, 2014).

29. National Wildlife Federation. May 2014. Migratory Birds and Tar Sands: 3–4. URL: http://www.nwf.org/~/media/PDFs/Global-Warming/2014/nwf_issue_briefs_Interactive2.pdf (accessed November 5, 2014).

30. Brandt, A. 2012 Variability and Uncertainty in Life Cycle Assessment Models for Greenhouse Gas Emissions from Canadian Oil Sands Production. Environmental Science & Technology. 46: 1253–1261. URL: http://priceofoil.org/content/uploads/2013/01/OCI.Petcoke.FINALSCREEN.pdf (accessed November 5, 2014).

31. National Energy Technology Laboratory. 2008. Development of Baseline Data and Analysis of Life Cycle Greenhouse Gas Emissions of Petroleum-Based Fuels. DOE/NETL-2009/1346. 13: table 2–4. URL: http://www.netl.doe.gov/File%20Library/Research/Energy%20Analysis/Publications/DOE-NETL-2009-1346-LCAPetr-BasedFuels-Nov08.pdf (accessed November 5, 2014).

32. Natural Resources Defense Council. 2010. Setting the Record Straight: Lifecycle Emissions of Tar Sands: 2. URL: http://docs.nrdc.org/energy/files/ene_10110501a.pdf (accessed November 3, 2014).

33. The separation is done by grinding, sorting, and the use of hot water or chemicals, all of which consume large amounts of energy. Swift, A. 2011. Tar Sands Pipeline Safety Risks: 5. National Wildlife Federation. Washington, D.C. URL: http://www.nwf.org/pdf/Tar-Sands/Tar%20Sands%20Pipeline%20Safety%20Risks.pdf (accessed November 6, 2014).

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34. Biello, D. January 15, 2013. More Oil from Canada’s Tar Sands Could Mean Game Over for Climate Change. Scientific American. URL: http://www.scientificamerican.com/article/more-oil-from-canadas-tar-sands-could-mean-game-over-climate-change/ (accessed November 6, 2014); Stockman, L. November 1, 2012. Tar sands planned growth is 3X carbon limit. PriceofOil.org. URL: http://priceofoil.org/2012/11/01/tar-sands-planned-growth-is-3x-climate-limit/ (accessed November 6, 2014).

35. National Wildlife Federation. Growth of Tar Sands Across Midwest. URL: http://www.nwf.org/What-We-Do/Energy-and-Climate/Drilling-and-Mining/Tar-Sands/Michigan-Oil-Spill.aspx (accessed November 7, 2014).

36. The substances used for dilution (“diluents”), tend to be flammable, toxic liquids derived from natural gas, such as natural gas condensate. See, Headwaters Initiative and Carrier Sekani Tribal Council, Fact Sheet: A Brief on Condensate and Diluents. URL: http://boldnebraska.org/uploaded/pdf/HeadwatersInitiative-CondensateFactSheet.pdf (accessed November 6, 2014); J.P. Morgan Ventures Energy Corp. and JP Morgan Commodities Canada Corp. February 1, 2013. Safety Data Sheet: Natural gas condensate, sweet or sour. URL: https://www.jpmorgan.com/directdoc/commodities_condensate.pdf (accessed November 5, 2014).

37. U.S. Department of State. August 26, 2011. Appendix L: Pipeline Temperature Effects Study, Final Environmental Impact Statement, Volume 7.L-2: Figure 1. URL: http://keystonepipeline-xl.state.gov/documents/organization/182235.pdf (accessed October 24, 2014).

38. Environment Canada (Emergencies Science and Technology). Fisheries and Oceans Canada (Centre for Offshore Oil, Gas and Energy Research), Natural Resources Canada (Canmet ENERGY). November 30, 2013. Properties, Composition and Marine Spill Behaviour, Fate and Transport of Two Diluted Bitumen Products from the Canadian Oil Sands : 5 and 19. URL: http://crrc.unh.edu/sites/crrc.unh.edu/files/1633_dilbit_technical_report_e_v2_final-s.pdf (accessed October 24, 2014); Paris, M. September 13, 2013. Enbridge’s Kalamazoo cleanup dredges up 3-year-old spill. CBC News. URL: http://www.cbc.ca/news/politics/enbridge-s-kalamazoo-cleanup-dredges-up-3-year-old-oil-spill-1.1327268 (accessed October 24, 2014).

39. Oil Change International. May 2014. Runaway Train: The Reckless Expansion of Crude-by-Rail in North America. URL: http://priceofoil.org/content/uploads/2014/05/OCI_Runaway_Train_Single_reduce.pdf (accessed August 11, 2014).

40. Ibid. at 4.

41. RBN Energy. 2014. Rock the Boat, Don’t Rock the Boat: Impact of the Jones Act on U.S. Crude Oil Markets (RBN Drill Down Report).(subscription only, available at URL: https://rbnenergy.com/subscriber/reports/previews/rock-the-boat-dont-rock-the-boat-impact-of-the-jones-act); Oil Change International report. May 2014. Runaway Train: the Reckless Expansion of Crude-by-Rail in North America. URL: http://priceofoil.org/content/uploads/2014/05/OCI_Runaway_Train_Single_reduce.pdf (see specifically the sidebar “Rolling down the river” for a discussion of barge movements on the Mississippi) (accessed August 25, 2014).

42. Alliance for the Great Lakes. November 20, 2013. Oil and Water: Tar Sands Crude Shipping Meets the Great Lakes? URL: http://www.greatlakes.org/document.doc?id=1425 (accessed November 5, 2014); Hussain, Y. October 16, 2014. Beyond Energy East: The great push to get Alberta’s crude to market. National Post. URL: http://business.financialpost.com/2014/10/16/beyond-energy-east-the-great-push-to-get-albertas-crude-to-market/?__lsa=4693-7b3f (accessed November 5, 2014).

43. Michael, H. March 25, 2014. BP Confirms Oil Spill Into Lake Michigan from Whiting Refinery. Chicago Tribune. URL: http://articles.chicagotribune.com/2014-03-25/news/chi-bp-whiting-crude-oil-lake-michigan-spill-20140325_1_whiting-refinery-oil-spill-scott-dean (accessed September 14, 2014).

44. Oil Sands International. January 2013. Petroleum Coke: The Coal Hiding in the Tar Sands: 4. URL: http://priceofoil.org/content/uploads/2013/01/OCI.Petcoke.FINALSCREEN.pdf (accessed November 4, 2014).

45. Lake Superior Streams. Duluth Drinking Water. URL: http://www.lakesuperiorstreams.org/understanding/drinking.html (accessed September 11, 2014).

46. Michael, H. .March 25, 2014. BP Confirms Oil Spill Into Lake Michigan from Whiting Refinery. Chicago Tribune. URL: http://articles.chicagotribune.com/2014-03-25/news/chi-bp-whiting-crude-oil-lake-michigan-spill-20140325_1_whiting-refinery-oil-spill-scott-dean (accessed September 8, 2014).

47. Illinois Environmental Protection Agency. Lake Michigan Monitoring Program. URL :http://www.epa.state.il.us/water/surface-water/lake-michigan-mon.html (accessed September 20, 2014).

48. Indiana American Water. 2007. 2007 Annual Water Quality Report. URL: http://www.gary.in.us/environmentalaffairs/pdf/care/INAmWater_info.pdf (accessed November 3, 2014).

49. Milwaukee Water Works. 2014. About the Milwaukee Water Works. URL: http://milwaukee.gov/water/about (accessed September 16, 2014).

50. City of Toledo. 2014. Division of Water Treatment. URL: http://toledo.oh.gov/services/public-utilities/water-treatment/ (accessed September 15, 2014).

51. FEIS. 2014. Alberta Clipper Project : 4-250. URL: http://mn.gov/commerce/energyfacilities/documents/33599/_C%201%20Loretta%20Cartner.pdf (accessed August 30, 2014).

52. United States Department of Agriculture—Forest Service. Chippewa National Forest—Bald Eagles and Heritage Resources. URL: http://www.fs.usda.gov/attmain/chippewa/specialplaces. The Chippewa National Forest, it should be noted, shares boundaries with the Leech Lake Reservation of the Anishinabe (Ojibwe/Chippewa) people, many of whom continue traditional ways of life close to the forest and its resources (accessed November 5, 2014).

53. Wildlife Viewing Areas. Suomi Hills Semi-Primitive Non-Motorized Area (Chippewa National Forest). URL: http://www.wildlifeviewingareas.com/wv-app/ParkDetail.aspx?ParkID=505 (accessed November 5, 2014).

54. United States Department of Agriculture—Forest Service. Chippewa National Forest—Lakes and Wetlands. URL: http://www.fs.usda.gov/attmain/chippewa/specialplaces (accessed November 5, 2014).

55. St. Louis River Citizens Action Committee. May 2002. Lower St. Louis River Habitat Plan : ix. URL: http://www.stlouisriver.org/habitatplan/habitatplan.pdf (accessed November 5, 2014).

56. Minnesota Land Trust. St. Louis River Restoration Initiative. URL: http://www.mnland.org/st-louis-estuary/ (accessed November 4, 2014).

57. Lake Superior National Estuarine Research Reserve,. February 3, 2014. Project Overview. URL: http://lsnerr.uwex.edu/index.html (accessed November 5, 2014).

58. Wisconsin State Parks and Forests. February 13, 2014. Brule River State Forest. URL: http://dnr.wi.gov/topic/stateforests/bruleriver/ (accessed November 5, 2014).

59. Ibid.

60. United States Fish and Wildlife Service. November 20, 2013. Necedah National Wildlife Refuge. URL: http://www.fws.gov/refuge/Necedah/wildlife_and_habitat/index.html (accessed November 4, 2014).

61. International Crane Foundation. Whooping Crane. URL: http://www.savingcranes.org/whooping-crane-conservation.html (accessed September 14, 2014).

62. Pryor, S. C., D. Scavia, C. Downer, M. Gaden, L. Iverson, R. Nordstrom, J. Patz, and G. P. Robertson. 2014. Ch. 18: Mid- west. Climate Change Impacts in the United States: The Third National Climate Assessment, J. M. Melillo, Terese (T.C.) Richmond, and G. W. Yohe, Eds., U.S. Global Change Research Program. 418–440. doi:10.7930/J0J1012N. URL: http://nca2014.globalchange.gov/system/files_force/downloads/low/NCA3_Full_Report_18_Midwest_LowRes.pdf?download=1 (accessed August 28, 2014).

63. Yeager-Kozacek, C. August 3, 2014. Toxic Algae Bloom Leaves 500,000 Without Drinking Water in Ohio. EcoWatch. URL: http://ecowatch.com/2014/08/03/toxic-algae-bloom-500000-without-drinking-water-ohio/ (accessed September 20, 2014).

64. Baehr, L., March 8, 2011. Lake Erie is Turning to Slime. Business Insider. URL: http://www.businessinsider.com/lake-erie-algal-blooms-are-out-of-control-2014-3 (accessed September 20, 2014).

65. National Environmental Education Foundation. Climate Change Influences Algal Blooms. URL: http://www.earthgauge.net/2014/climate-change-influences-algal-blooms (accessed November 3, 2014).

66. University of Wisconsin-Madison. 2011. Wisconsin’s Changing Climate: Impacts and Adaptation, Chapter 3—Water Resources: 55. URL: http://www.wicci.wisc.edu/report/WICCI-Chapter-3.pdf (accessed November 5, 2014).

67. Koslow, M. June 28, 2012. Thoughts On a New Normal. National Wildlife Federation. Washington, D.C. URL: http://blog.nwf.org/2012/06/thoughts-on-a-new-normal/ (August 17, 2014).

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68. Plume, C. August 2, 2012 Drought Worsens in U.S. Farm States: Climatologists. Reuters. URL: http://www.reuters.com/article/2012/08/02/us-drought-idUSBRE87110A20120802 (accessed September 2, 2014).

69. McGowen, E and Song, L. June 26, 2012. The Dilbit Disaster: Inside the Biggest Oil Spill You’ve Ever Heard of, Part One. Inside Climate News. URL: http://insideclimatenews.org/news/20120626/dilbit-diluted-bitumen-enbridge-kalamazoo-river-marshall-michigan-oil-spill-6b-pipeline-epa (accessed September 2, 2014).

70. Michigan Department of Community Health. December 20, 2010. Acute Health Effects of the Enbridge Oil Spill. URL: http://www.michigan.gov/documents/mdch/enbridge_oil_spill_epi_report_with_cover_11_22_10_339101_7.pdf (accessed September 9, 2014).

71. Hasemyer, D. December 32, 2013. Enbridge Dilbit Spill Still Not Cleaned Up as 2013 Closes, Irritating the EPA. Inside Climate News. URL: http://insideclimatenews.org/news/20131223/enbridge-dilbit-spill-still-not-cleaned-2013-closes-irritating-epa (accessed September 15, 2014).

72. Ibid.

73. United States Fish and Wildlife Service. September 15, 2010. Statement of the U.S. Fish and Wildlife Service, Department of the Interior, on the Enbridge Pipeline Oil Spill Near Marshall, Michigan before the House Committee on Transportation and Infrastructure. URL: http://www.fws.gov/midwest/oilspill/documents/statement.pdf (accessed on August 20, 2014).

74 Ibid.

75. National Transportation Safety Board. July 10, 2012. Report— Kalamazoo Pipeline Spill : xii. URL: http://www.ntsb.gov/doclib/reports/2012/par1201.pdf (accessed August 11, 2014).

76. Ibid.

77. National Transportation Safety Board. Press Release. July 10, 2012. URL: http://www.ntsb.gov/news/2012/120710.html/ (accessed August 5, 2014).

78. “[O]il exiting a pinhole may create a medium to large spill due to difficulties for supervisory control and data acquisition or aerial surveillance to detect such a leak.” Keystone XL Draft Environmental Impact Statement. March 2013. Affected Environment—Operation: 3.13–17. URL: http://keystonepipeline-xl.state.gov/documents/organization/205638.pdf (accessed November 5, 2014).

79. Enbridge. 2009 and 2013. Corporate Responsibility Report. URL: http://www.enbridge.com/AboutEnbridge/CorporateSocialResponsibility/CSRReports.aspx (accessed November 4, 2014).

80. National Transportation Safety Board. June 23, 2004. Rupture of Enbridge Pipeline and Release of Crude Oil near Cohasset, Minnesota July 4, 2002. Pipeline Accident Report NTSB/PAR-04/01: 3, URL: www.ntsb.gov/doclib/reports/2004/PAR0401.pdf (accessed August 5, 2014).

81. Only the southern portion of the Pegasus pipeline had been re-opened. Associated Press. ExxonMobil restarts Pegasus pipeline in Texas. URL: http://www.washingtontimes.com/news/2014/jul/30/exxonmobil-restarts-pegasus-pipeline-in-texas/ (accessed November 3, 2014).

82. Song, L. June 18, 2013. What Sickens People in Oil Spills, and How Badly, Is Anybody’s Guess. InsideClimateNews. URL: http://insideclimatenews.org/news/20130618/what-sickens-people-oil-spills-and-how-badly-anybodys-guess (accessed August 15, 2014).

83. Canadian Association of Petroleum Producers. June 2014. Crude Oil Forecast. Markets & Transportion: 13. URL: http://www.capp.ca/getdoc.aspx?DocId=247759&DT=NTV (accessed October 22, 2014).

84. Dhillon, K. April 17, 2014. Why are U.S. Oil Imports Falling. TIME.com. URL: http://time.com/67163/why-are-u-s-oil-imports-falling/ (accessed October 22, 2014).

85. United States Energy Information Administration. U.S. Field Production of Crude Oil, Monthly, 1920—August 2014. URL: http://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=MCRFPUS2&f=M (accessed November 3, 2014).

86. These are owned by Enbridge Inc., a Canadian company. Enbridge. Liquid Pipelines—Mainline. URL: http://www.enbridge.com/DeliveringEnergy/OurPipelines/LiquidsPipelines.aspx (accessed November 4, 2014).

87. While most Enbridge pipelines running through the Great Lakes region are owned by Enbridge’s U.S. branch, Enbridge Energy Partners L.P., certain (e.g., Line 17 to Toledo), are owned straight out by Enbridge Inc., the Canadian parent company. Enbridge Inc. Liquids Pipelines.

URL: http://www.enbridge.com/DeliveringEnergy/OurPipelines/LiquidsPipelines.aspx (accessed November 3, 2014). Enbridge’s “Midcontinent system, which includes Line 55 (“Spearhead”) between Flanagan IL and Cushing OK, as well the Mustang and Chicap lines connecting Chicago to Patoka are also owned by Enbridge Inc. Ibid. Enbridge Inc. holds a 21.1 percent ownership interest in Enbridge Energy Partners L. P. Enbridge. About Enbridge—Corporate Overview. URL: http://www.enbridge.com/AboutEnbridge/CorporateOverview.aspx (accessed November 3, 2014).

88. “As a transporter of energy, Enbridge operates, in Canada and the U.S., the world’s longest crude oil and liquids transportation system.” Enbridge. September 25, 2014. News Release (text in footer). URL: http://www.enbridge.com/~/media/www/Site%20Documents/Investor%20Relations/2014/2014_ENB_Day_Advisory.pdf (accessed November 3, 2014); Enbridge states: “We transport energy, operating the world’s longest, most sophisticated crude oil and liquids transportation system.” Enbridge. About Enbridge—Corporate Overview. URL: http://www.enbridge.com/AboutEnbridge/CorporateOverview.aspx (accessed November 3, 2014).

89. Enbridge Inc. Liquids Pipelines. URL: http://www.enbridge.com/DeliveringEnergy/OurPipelines/LiquidsPipelines.aspx (accessed November 3, 2014).

90. At present, the other Alberta to U.S. pipeline carrying heavy tar sands crude is Line 4, but for various reasons, including the fact that it is used to transport other types of crude as well, Line 4 is not the centerpiece of industry’s expansion plans. Minnesota Public Utilities Commission. June 27, 2014. PL9/CN-13-153 In the Matter of the Application of Enbridge Energy, Limited Partnership for a Certificate of Need for the Line 67—Phase 2 Upgrade Project. Docket PL9/CN-13-153. URL: https://www.edockets.state.mn.us/EFiling/edockets/searchDocuments.do?method=showPoup&documentId=%7B561DC6CE-AE98-465B-90E8-0B0A3EA404CF%7D&documentTitle=20146-100926-01 (accessed November 4, 2014).

91. Figure derived from: Oil Change International. 2012. Refinery Report. URL: http://refineryreport.org/refineries-list.php (accessed November 4, 2014).

92. Song, L. June 3, 2013. Map: Another Major Tar Sands Pipeline Seeking U.S. Permit. InsideClimateNews. URL: http://insideclimatenews.org/news/20130603/map-another-major-tar-sands-pipeline-seeking-us-permit (accessed November 7, 2014).

93. Natural Resources Defense Council. July 30, 2012. Scoping Comments of the Natural Resources Defense Council, et al., to the Department of State on the Supplemental Environmental Impact Statement for the TransCanada Keystone XL Pipeline. URL: http://switchboard.nrdc.org/blogs/aswift/NRDC%20et%20al%20KXL%20SEIS%20Scoping%20Comments%20FINAL%20July%2030%202012.pdf (accessed August 15, 2014).

94. Minnesota Public Utilities Commission. July 17, 2013. PL9/CN-12-590 In the Matter of the Application of Enbridge Energy, Limited Partnership for a Certificate of Need for the Line 67 Station Upgrade Project in Marshall, Clearwater, and Itasca Counties, Minnesota. Docket PL9/CN-12-590. URL: https://www.edockets.state.mn.us/EFiling/edockets/searchDocuments.do?method=showPoup&documentId={A3D9DD5C-CF23-4EA7-A021-B30D325AD2BB}&documentTitle=201210-79329-10 (accessed November 4, 2014); August 28, 2014, PL9/CN-13-153, In the Matter of the Application of Enbridge Energy, Limited Partnership for a Certificate of Need for the Line 67 Station Upgrade Project—Phase 2 in Kittson, Red Lake, Cass, and St. Louis Counties, Minnesota. URL: https://www.edockets.state.mn.us/EFiling/edockets/searchDocuments.do?method=showPoup&documentId={F1B13575-3D71-4CAA-A86A-05CE1EBBCA38}&documentTitle=20138-90363-03 (accessed November 4, 2014).

95. Shaffer, D. August 27, 2014. Pipeline changes will send more Canadian oil into Minnesota. StarTribune. URL: http://www.startribune.com/business/272089211.html (accessed September 2, 2014).

96. The original Presidential permit was granted in 2009. U.S. Department of State. August 20, 2009. Permit for Alberta Clipper Pipeline Issued (Media Note). URL: http://www.state.gov/r/pa/prs/ps/2009/aug/128164.htm (accessed August 10, 2014).

97. 42 U.S.C.A. § 4332 (West); Executive Order 13337, Issuance of Permits With Respect to Certain Energy-Related Facilities and Land Transportation Crossings on the International Boundaries of the United States, 69 FR 25299, April 30, 2004.

98. Executive Order 11423, 33 Fed. Reg. 11741 (Aug. 16, 1968), as amended by

26 | NATIONAL WILDLIFE FEDERATION

Executive Order 13337, 69 Fed. Reg. 25229 (Apr. 30, 2004); 40 C.F.R. § 1502.9, 43 Fed. Reg. 55994 (Nov. 29, 1978).

99. Enbridge Inc. 2014. Line 61 Upgrade Project—Phase 1. URL: http://www.enbridge.com/MainlineEnhancementProgram/US/Line61UpgradeProjectPhase1.aspx (accessed September 6, 2014).

100. Reed, M. November 2013. Projects Reflect Midstream Expansion, Restructuring. Pipeline and Gas Journal. URL: http://www.pipelineandgasjournal.com/projects-reflect-midstream-expansion-restructuring?page=show (accessed August 24, 2014).

101. BakkenOilReport. May 8, 2013. No Crude Left Behind. URL: http://bakkenoilreport.com/no-crude-left-behind/ (accessed September 5, 2014).

102. Sierra Club, Inc. v. Bostick, CIV-12-742-R, 2012 WL 3230552 (W.D. Okla. Aug. 5, 2012) aff’d, 539 F. App’x 885 (10th Cir. 2013). NWF and Sierra Club argue that federal agencies erred in approving the project via a grievous misapplication of an obscure Army Corp of Engineers permitting process, resulting in a shamelessly flawed, piecemeal approval process.

103. Enbridge Inc. September 2014. Investment Community Presentation: 23. URL: http://www.enbridge.com/~/media/www/Site%20Documents/Investor%20Relations/2014/2014_ENB_Investment%20Community%20Booklet.pdf (accessed October 22, 2014); Lewis, J. October 8, 2014. New Enbridge pipeline could give Alberta crude another conduit to world markets. The Globe & Mail. URL: http://www.theglobeandmail.com/report-on-business/industry-news/energy-and-resources/new-enbridge-pipeline-could-give-alberta-crude-another-conduit-to-world-markets/article20993504/ (accessed November 4, 2014).

104. Energy Transfer Partners. November 20, 2013. 2013 Analyst Presentation: 23. URL: http://phx.corporate-ir.net/External.ile?item=UGFyZW50SUQ9MjI2MjkyfENoaWxkSUQ9LTF8VHlwZT0z&t=1 (accessed August 13, 2014); Song, L. August 4, 2013. Little known pipeline nearly as big as Keystone could win the race to the Gulf. Inside Climate News. URL: http://insideclimatenews.org/news/20130804/map-little-known-pipeline-nearly-big-keystone-could-win-race-gulf (Accessed August 13, 2014).

105. Originally, Energy Transfer Partners hoped to also build a 160-mile extension at the southern end, to Saint James LA, RBN Energy, which is not far from the largest waterborne crude oil import terminal in the U.S., the Louisiana Offshore Oil Port or LOOP. That extension has been put on ice—for now. Houston (Platts). November 6, 2013. Eastern Gulf Crude Access pipeline won’t be linked to St. James: ETP. URL: http://www.platts.com/latest-news/oil/houston/eastern-gulf-crude-access-pipeline-wont-be-linked-21786375 (accessed August 11, 2014); Fielden, S. December 23, 2012. Thrown for a LOOP—Crude Imports and the Louisiana Offshore Oil Port Terminal. RBN Energy. URL: https://rbnenergy.com/thrown-for-a-loop-the-louisiana-offshore-oil-port-terminal (accessed August 11, 2014).

106. It would avoid the current crooked path that crude headed for the Gulf must currently follow, through the congested Cushing OK pipeline interchange. Eastern Gulf Crude Access Pipeline Project. June 5, 2013. Information Memorandum and Notice of Binding Open Season. URL: http://www.energytransfer.com/documents/PublicInformationMemorandum.pdf (accessed November 4, 2014).

107. According to a key energy blog, EGCAP was “pitched at exactly the same time as a complimentary project operated by Enbridge that would link the latter’s huge Lakehead system running from Western Canada to Flanagan, IL with EGCAP in Patoka.” Fielden, S. June 11, 2013. The Enbridge SAX and East Gulf Pipeline Band—Music to Canadian Crude Producer’s Ears! RBN Energy. URL: https://rbnenergy.com/the-enbridge-sax-and-east-gulf-pipeline-band (accessed August 10, 2014).

108. The segment between Griffith and Stockbridge was completed in May 2014, and Enbridge expects to finish the Ortonville, MI-to-Saint Clair River segment in the Fall of 2014. Enbridge Inc. September 2014. Investment Community Presentation: 25, URL: http://www.enbridge.com/~/media/www/Site%20Documents/Investor%20Relations/2014/2014_ENB_Investment%20Community%20Booklet.pdf (accessed October 22, 2014).

109. Enbridge Energy Management LLC. May 2, 2014. SEC Filing Form—10-Q: 53—U.S. Mainline Expansions. URL: http://www.enbridgemanagement.com/Investor-Relations/EEQ/Financial-Information/SEC-Filings/ 9565617/220095/ (accessed August 2, 2014).

110. Enbridge Inc. 2012-2013. Line 78 Pipeline Project. URL: http://www.enbridge.com/~/media/www/Site%20Documents/Delivering%20Energy/Projects/US/ENB2013-Line78-L11.pdf?la=en (accessed August 2, 2014).

111. Enbridge Inc. September 30, 2014. Enbridge Day 2014 Annual Investment Community Conference – Toronto, September 30, 2014, (transcript):19. URL: http://www.enbridge.com/~/media/www/Site%20Documents/Investor%20Relations/2014/ENBDays/2014_ENB_Days_Transcript.pdf (accessed November 2, 2014).

112. Ibid.

113. Enbridge. February 11, 2014. Letter to Wisconsin Conservation Commission. URL: https://doc-10-7g-apps-viewer.googleusercontent.com/viewer/secure/pdf/hf65vmt9gsnnfbahqirkkav0p2c91plk/ 1dhf45e1n8oj474v01ocefp3dsmlp4c5/1414992750000/gmail/06836116497116554278/ACFrOgDVbep3AtbLZmmS9sExfvan-3sucwvTXnOYqI6AAl7oMsQP0u1cc5KAknwyHuFBCQEFPB_jNB8TeyDtq51Ci1LUm8wg9Xmsgk62_zg5PMjNhT1tS-k37EAD1uk=?print=true&nonce=235lcu9fn5nqm&user=06836116497116554278&hash=n11769212kcjobrkq3ist8a9p9428fla (accessed November 3, 2014);Friends of the Headwaters. August 21, 2014. Comments on Consideration of System Alternatives and the Legal Basis for Consideration of System Alternatives in the Need and Routing Proceedings. Submission to the Minnesota Public Utilities Commission in matters concerning the proposed Sandpiper project, dockets PL-6668/CN-13-473 and PL-6668/CN-13-473: 17. URL: http://www.friendsoftheheadwaters.org/uploads/3/4/4/2/3442631/foh_comments_8_21.pdf. (accessed November 3, 2014). As evident in the Friends of the Headwaters comments, some believe this line may be called “Line 66, but this seems unlikely since there is already another Line 66 in the Midwest, more frequently referred to as the Mustang pipeline. The new WI-IL Pipeline could be as much as 800,000 barrels per day.

114. The White House—Office of the Press Secretary. June 25, 2013, 1:45 P.M. Remarks by President on Climate Change. Georgetown Univer-sity. Washington, D.C. URL: http://www.whitehouse.gov/the-press-office/2013/06/25/remarks-president-climate-change (accessed September 6, 2014).

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