[All] Line 9 update: The PEO
jkliggett at rogers.com
jkliggett at rogers.com
Thu Jan 9 11:54:36 EST 2014
I haven't read all of the below emails (on holidays) but my immediate thoughts are that they have a professional code that they should live & work by. If they are squirming in discomfort they should be speaking out. As members of the executive of THEIR PROFESSIONAL ass'n, they owe it to the public to speak out as a body on their concerns. Where is the PEO's official statement on this? Why is it we the public who have to do their work as well as our own?
Sorry, but no prisoners here.
Jan
iPad email
> On Jan 9, 2014, at 12:44 AM, Louisette Lanteigne <butterflybluelu at rogers.com> wrote:
>
> Hello everyone.
>
> I wrote a letter asking for the Professional Engineers Ontario to review the engineering data used at the NEB hearing for Line 9 by Enbridge. They declined to help and returned all of my material to me, however I wrote to every member of their executive board and in response, they started sending me emails sharing their "personal" views on the issue. Below are all the emails I sent and received in regards to this matter. (first letter sent is the last one on the list so it's all in reverse order)
>
> It is EVIDENT from the correspondences provided below, that various members of the Professional Engineers Ontario (PEO) share the concern that the current risk mitigation strategies to protect the public interest and to protect our Province from significant liability issues associated with poor engineering practices is not working as effectively as it should. Many share our concerns regarding Line 9. They want to help but are limited in their powers to do so but there appears to be conflicting views as to what exactly their jurisdictional powers are.
>
> It appears that discretionary powers are being used by the Government that is restricting the reasonable use of the PEO to fulfill it's duty in preventing public risks and in securing compliance to the Professional Engineers Act. They give voice to this in their written responses many times.
>
> I share this with you all in good faith. I think it's reasonable to state that we all believe this is a matter of absolute and qualified privileges and in my view this reflects issues of a National Security Risk. I'd like to proceed to do something with these correspondences but I'd like to take a collaborative and coordinated approach. I don't want to compromise these individuals in any way at all. These letters are CONFIDENTIAL but from them we can glean the ideas we need to craft to get our strongest points to help improve the system but it has to be done in a way that protects and respects everyone.
>
> So many of our environmental concerns are based on the quality of the engineering data. We need to make sure the folks at the top have clarity on their jurisdictional powers and the right to review issues reasonably otherwise all the other tiers under them will be ineffective at assuring compliance is reasonably met.
>
> Lulu
>
>
>
> ----- Forwarded Message -----
> From: G P Wowchuk <gwowchuk at aol.com>
> To: butterflybluelu at rogers.com
> Sent: Wednesday, January 8, 2014 6:21:52 PM
> Subject: Enbridge pipeline issue and PEO
>
>
> Hello, Louisette--
>
> Your correspondence with Denis Dixon, a former president of Professional Engineers Ontario, somehow crossed my desk (screen?), and I thought I would offer some comments from my own perspective. I believe Mr Dixon's comments were coloured by his own political ambition, so it is desirable that you hear from other members of the profession.
>
> I am a former PEO councillor and Executive Analyst, and a citizen activist in my own right. That activism began in 1971, when a group in my neighbourhood successfully fought at the OMB a mega-garbage incinerator slated to be built by Metro Toronto several blocks from us. We also successfully fought a crematorium slated for our area (although we lost at the OMB). We also opposed the giant 990-unit highrise condo buildings at Sherway Gardens in south Etobicoke (which we lost at the OMB, and which buildings since have been erected). In 2003 and 2006, I ran (unsuccessfully) for Toronto City Council, largely on a platform related to the neglect of engineering and planning in our cities.
>
> My family is from central-west Manitoba, where, on vacation, I was pressed into service at provincial environmental hearings concerning Louisiana-Pacific's proposal to build a particle-board factory in the middle of some of the best agricultural land in the province. Those hearings were a complete farce. I found numerous errors in the modelling and calculations of the engineering report, but, not being an expert (I'm an electrical engineer), and not being licensed in Manitoba, I did not file an official complaint with the regulator. In the last fifteen years, L-P has monopolized the local logging business, generated huge amounts of airborne and ground-water pollution, broken up the roads, and employs only a small fraction of the people promised jobs during its proposal.
>
> The lesson I have learned over these years is that projects like these, we all know they will be a net detriment to the environment and the people who have to live near them. It is not a matter of engineering, it is a matter of pure politics. Occasionally, as we have seen in the Quebec inquiry into construction contracts, there is outright corruption involved. More frequently, however, politicians and political parties are simply beholden to those who finance them. The individual engineer in many of these cases simply is trying to earn a (meagre) living, but the real decision-making power resides in business and political entities above him. I believe former PEO president Pat Quinn also made that point about the Elliot Lake mall tragedy.
>
> PEO does have the power to discipline individual engineers who, through negligence or corruption, has proffered bad engineering to support a bad project. As Dr Quinn has told you, PEO also ought to be--but isn't--more active in standing up to political entities who misuse engineers and engineers to support bad development. However, detailing the individual engineer's responsibility to society at large is more grey-area than proving he made erroneous calculations and conclusions in an engineering report, so PEO usually goes after the latter.
>
> Mr Dixon's suggestion of a "Provincial Engineer" is his own political concoction, one that was never taken seriously at Council. It will never see the light of day, because it essentially would cede control from a statutory self-regulating profession to an employee of the provincial government. As those of us who have fought bad development in the past have seen, government is our adversary, not our deliverer.
>
> The courts (including pseudo-judicial bodies like the Ontario Municipal Board) also have not been our deliverer. Large companies always hire the best experts and the best lawyers. Citizen victories there are exceedingly rare. In fact, the courts themselves have suggested not to bother them about political matters. A few years ago, the Canadian Taxpayers' Federation filed a suit against the provincial government, which scant weeks after Dalton McGuinty signed a pledge not to increase our taxes, instituted major levies on our health-care premiums. The court said, don't come to us about political matters, the correct venue is the ballot box.
>
> So... the reality is that your best hope of progress, in my opinion, is to build a political force against this project. You need to have experts (yes, engineers) say precisely what is wrong with the design. You need to expose any corruption or political back-rooming which tainted the decision. You need media and social-media contagion. (Remember "news" is something unexpected. If just the usual NIMBYism, it simply won't get picked up.) You need to threaten, by your numbers, the politicians involved in the decision-making. The natural-gas generating plant slated for a location next to my riding in south Etobicoke was abruptly cancelled, when our MPP, Laurel Broten, was in danger of losing her seat because of the backlash.
>
> That is the best advice I can give you, from one who's been there and got the T-shirt. It is truly a daunting task.
>
> Gregory P Wowchuk, P Eng
>
>
> ----- Forwarded Message -----
> From: Denis Dixon <ddixon at netrover.com>
> To: Louisette Lanteigne <butterflybluelu at rogers.com>
> Sent: Tuesday, January 7, 2014 2:17:19 PM
> Subject: Experts
>
> I note that today you received a communication from PEO member Quinn. His opinions are correct in only some of his points and they do not represent PEO. In some matters he is incorrect in what PEO can do.
>
> I took the liberty of sending the correspondence between us to John Clayton. John is not in particularly good health but is a long time advocate and activist. He has had a career as a failure analyst, before which he was involved in the pipeline industry. John has a wealth of knowledge about the subject and is interested in communicating with you. I have a 25 year professional relationship with John and know that he is so busy he rarely gets round to calling folks. But if you were to phone him, it would likely be beneficial to you
>
> He is in Brampton, his company Famex at 905 840 3110.
>
> I will be speaking next week with the new Registrar and with the Chair of the Professional Standards Committee about your issue.
>
> Best regards,
>
> Denis Dixon.
>
> Lulu :0)
>
> ----- Forwarded Message -----
> From: Pat Quinn <pquinn0121 at rogers.com>
> To: Louisette Lanteigne <butterflybluelu at rogers.com>
> Sent: Tuesday, January 7, 2014 1:25:41 PM
> Subject: Re: ENBRIDGE LINE 9
>
> Attachment:
>
> From: Pat Quinn
> Sent: Tuesday, January 07, 2014 1:19 PM
> To: Louisette Lanteigne
> Subject: ENBRIDGE LINE 9
>
> Dear Louisette Lanteigne,
> Many thanks for bringing your concerns regarding this pipeline to a wider audience, and for contacting PEO.
> Your correspondence reached my inbox, and I hope you will consider some comments of mine.
>
> You are told that PEO lacks power to intervene (incorrect); that this might have something to do with government not proclaiming changes to the Industrial Exemption (a red herring); and that PEO has “no apparent jurisdiction over Enbridge” (incorrect). Also that a new office of Provincial Engineer might somehow help, (it won’t, a government appointee will make PEO superfluous; there are various ministries already filling any voids in PEO’s jurisdiction from a public safety aspect, e.g. The Ministry of Labour).
>
> PEO clearly has jurisdiction over Enbridge’s engineering enterprises, and there are a number of ways that The Engineers Act allows interventions.
> It could also commission a pro/con report by an eminent committee to clarify the issues and assist in the debate as an independent authority. This is perhaps a futile hope as PEO is an organisation that has traditionally relied heavily on input regulation, licensing; rather than on output regulation, oversight of the practice of those who are licensed.
> (I attach my commentary on the Algo Mall collapse in which I comment on my view of PEO in Section 3).
>
> While PEO is not fulfilling its responsibilities in providing standards and guidelines for pipeline design and safety, and for professional reviews of pipes line engineering issues, (areas within the definition of professional engineering), your concerns cannot be solved by engineers, who, like many in our society, have conflicting views on progress, societal risks, and many of the other areas of contention today.
> With respect to pipelines, there are engineers who argue in good faith that they are inherently too risky, and others of equally good faith who are prepared to accept that the risk/benefit equation favours benefits. Experience has shown that PEO’s use of the Complaints process to settle disputes between experts is inappropriate. PEO standards however would encourage more objective reports, in that performance would have measures by which it could be professionally judged.
>
> There is no doubt that there are areas where public benefit and degrees of acceptable risk have to be weighed in the balance, and while engineers should bring objective values to the debate, their reports are opinions influenced by their own view of the world, so with an issue with considerable subjective parts, it is not surprising that they can appear on both sides of the debate.
> However divergent or extreme differences there are in the debate on an important topic, I believe that trying to suppress information is bad. Committees expect widely different perceptions on issues and have a duty to bring fairness and convergence to bear.
> When it comes to public safety and acceptable risks, we rely on our elected representatives, and it is they who must, having considered all the information, make final decisions in the risk/benefit equation in the public arena.
>
> I share your concerns and commend you for your activism and offer my support if I can help.
>
> Pat Quinn P.Eng.
>
>
> ----- Forwarded Message -----
> From: Denis Carlos <deniscarlos.qc9z at ncf.ca>
> To: Louisette Lanteigne <butterflybluelu at rogers.com>
> Cc: Denis Dixon <ddixon at netrover.com>; "abergeron at peo.on.ca" <abergeron at peo.on.ca>; "ddixon at peo.on.ca" <ddixon at peo.on.ca>; "daveadams at wightman.ca" <daveadams at wightman.ca>; "thomas.chong at rogers.com" <thomas.chong at rogers.com>; "sausma at peo.on.ca" <sausma at peo.on.ca>; "huangr at bennettjones.com" <huangr at bennettjones.com>; "ibhatia at peo.on.ca" <ibhatia at peo.on.ca>; "michael at wesa.peo.on.ca" <michael at wesa.peo.on.ca>; "rafraser at uwaterloo.ca" <rafraser at uwaterloo.ca>; "bdony at peo.on.ca" <bdony at peo.on.ca>; "rjones at peo.on.ca" <rjones at peo.on.ca>; "ctaylor at peo.on.ca" <ctaylor at peo.on.ca>; "dbrown at peo.on.ca" <dbrown at peo.on.ca>; "carlos.qc9z at ncf.ca" <carlos.qc9z at ncf.ca>; "csadr at peo.on.ca" <csadr at peo.on.ca>; "lking at peo.on.ca" <lking at peo.on.ca>; "ekuczera at peo.on.ca" <ekuczera at peo.on.ca>; "dchui at peo.on.ca" <dchui at peo.on.ca>; "rwillson at peo.on.ca" <rwillson at peo.on.ca>; "sgupta at peo.on.ca" <sgupta at peo.on.ca>; "vkossta at peo.on.ca" <vkossta at peo.on.ca>; "rhilton at peo.on.ca" <rhilton at peo.on.ca>; "jlee at peo.on.ca" <jlee at peo.on.ca>; "mirwin at peo.on.ca" <mirwin at peo.on.ca>; "croney at peo.on.ca" <croney at peo.on.ca>; "tarsem.sharma at humber.ca" <tarsem.sharma at humber.ca>; "rshreewastav at peo.on.ca" <rshreewastav at peo.on.ca>; "sreid at peo.on.ca" <sreid at peo.on.ca>; "mstauch at peo.on.ca" <mstauch at peo.on.ca>
> Sent: Tuesday, January 7, 2014 10:20:08 PM
> Subject: Re: Engineering concerns regarding Enbridge's data for Line 9
>
> Dear Louisette:
>
> This is the other Denis you had sent your email to.
>
> Your first letter was correct in approaching PEO for an engineering related public safety matter.
> Sorry you were misled by my namesake.
>
> Best regards,
> Denis Carlos
>
>
>> On 13-12-31 04:39 AM, Louisette Lanteigne wrote:
>> Hi Mr. Dixon
>>
>> Thank you so much for your letter. I am so thankful to have a better understanding of the jurisdictional limitations of the PEO. I see many government departments facing similar situations these days.
>>
>> Sometimes it takes really bad data to generate enough the social pressure to help reform and reshape policy and governance. I'm looking at Line 9 with an odd mixture of frustration and optimism.
>>
>> At this point in time, Line 9 Phase 1, from Sarnia to Westover has been fully approved by the NEB. In November we had the NEB hearing regarding phase B from Westover to Montreal and the NEB is still making it's decision regarding Phase B.
>>
>> ( Please note that Enbridge coined the terms Phase 1 and Phase B. Technically, Phase 2 and Phase A don't actually exist. Equiterre mentioned this fact at the NEB hearing.)
>>
>> The pipeline safety report produced by Accufacts is in the attachment and highlights the concerns regarding the pipeline's structural integrity issues.
>>
>> At this time the Provincial Policy Statement is being reviewed, and I'm thinking perhaps there is an opportunity to raise attention on the need to secure a Provincial Engineering Investigator.
>>
>> Land use issues and infrastructure are big topics for many municipalities. We are at the point where 80% of our infrastructure is close to end of life and requires repairs and/or replacing. It seems timely to propose putting system to help protect municipalities from liability risks associated with projects that may be based on poor engineering practices.
>>
>> Over the last few years, I assisted community groups in stopping or modifying projects that used flawed EA data for approval processes. These were the ones I was involved with:
>>
>> -Rockway Quarry: Cancelled at OMB
>> -Nelson Quarry in Burlington: Cancelled at OMB
>> -Tiny Township Landfill: Cancelled
>> -Highland Quarry in Melancthon: Cancelled
>> -St. Mary’s Quarry Flamborough: Cancelled
>> -West Side Lands OMB hearing PL071044: Secured new EA data.
>>
>> Common issue: Water supplies were at risk. Discretionary powers were used to undermine risks for the sake of approval. Concerned residents organized to reveal flawed data and economic risks which successfully cancelled or modified these projects to have regard for ecological constraints.
>>
>> There is another common denominator: All these projects used data by the same engineering firm. It may be a co-incidence. These issues may exist with other firms but in my experience this particular company's name keeps showing up over and over again and when it does, I usually find the issues are very consistent due to the following:
>> Poor test times and methods for fisheries and rare species
>> Odd mapping: missing features or other anomalies
>> Lack of regard for delta water levels associated with spring thaw
>> Lack of 12 month creek studies and reasonable benthic data
>> Poor bore hole data, too shallow and too few
>> The use of out dated data without regard for post development impacts
>> Modflow models without regard for sediment types or quarterly geology data.
>> Modflow data is subjective, difficult to replicate and often assume that aquifers are self contained
>> Over reliance on bore holes in out-wash moraine systems which gives false readings. (Clay layers are distributed like shingles on a rooftop. May appear impervious with bore hole data but ground penetrating radar is needed because these systems often have areas of pure recharge in between the shingle like effect.)
>> Lack of regard for draw down impacts with water taking
>> This firm also handled the EA for Enbridge Line 9 reversal.
>>
>> A few months ago, I spoke with a person involved with the Charbonneau Inquiry. I told this individual that we are observing more and more bad projects placing municipal water systems at risk. There is a pattern of bad data repeating. This person confirmed that, the main issues of corruption in construction is related to roads and water infrastructure.
>>
>> There appears to be a more organized effort to downplay risks of projects that threaten water resources and in my view, it's on a much larger scale than one or two bad engineers. It's a web. To brake it, we need to cut the gravy train.
>>
>> I presented this first concept at the Enbridge Line 9 phase 1 hearing. Firms who conduct insufficient Environmental Assessments sign off on their work and are no longer liable for the damages the flawed data may create, but they do stand to profit if it creates problems they get paid to fix. One way to avoid that issue is if their clients hold a check worth the value of their services, and later on if problems arise due to the bad EA, those clients should reserve the right to cash that check. We need systems in place to assure that liability falls on those who create problems and not simply demonize those who purchased the data. When I shared that concept at the first Line 9 hearing, I got handshakes from Ecojustice and Environmental Defense, as well as the folks at Suncor and Enbridge. Everyone agreed it was a good concept on all sides of the issue so there's a starting point we can build on.
>>
>> Other things we could use:
>> Standardized provincial test times and methods.
>> Standardize Units of measurements for clarity in planning processes.
>> Standardize species specific tests to protect endangered species. (I know several examples of how flawed testing, inappropriate equipment and lack of training resulted in the death of rare species)
>> Set a criteria for what is deemed "outdated" data.
>> Make data transparent, especially regarding water issues. It's a public commodity and the data on it should be too.
>>
>> Benefits: Better data helps to reduce risks and associated costs. Better decisions happen when the public and agencies are on the level with the issues.
>>
>> I've seen many OMB hearings as a result of developers undermining the intelligence of the public using shoddy EA data. It cost them millions at the OMB and in the end projects were cancelled or concessions were made to protect the natural features they should have protected to begin with. Better Provincially mandated testing criteria could have avoid these issues at the planning stage prior to approval rather than depleting the funds of all sides at an OMB hearing after the fact.
>>
>> I don't know if your group has the ability to provide policy recommendations of this nature but if so, that would be a very good thing to see.
>>
>> As for the concept of establishing a Provincial Investigative Engineer, I think it is an excellent idea. It's reasonable, sensible and very much needed in order to help protect the public interest. When the time comes to promote the concept with the public, please let me know. I would be more than happy to help build public support for it.
>>
>> Thank you so much for your thoughtful letter. If I get any updates at all on the status of Line 9 B I will be sure to send it along.
>>
>> Louisette Lanteigne
>> 700 Star Flower Ave.
>> Waterloo Ont.
>> N2V 2L2
>>
>> From: Denis Dixon <ddixon at netrover.com>
>> To: Louisette Lanteigne <butterflybluelu at rogers.com>; abergeron at peo.on.ca; ddixon at peo.on.ca; daveadams at wightman.ca;thomas.chong at rogers.com; sausma at peo.on.ca; huangr at bennettjones.com; ibhatia at peo.on.ca; michael at wesa.peo.on.ca;rafraser at uwaterloo.ca; bdony at peo.on.ca; rjones at peo.on.ca; ctaylor at peo.on.ca; dbrown at peo.on.ca; carlos.qc9z at ncf.ca; csadr at peo.on.ca;lking at peo.on.ca; ekuczera at peo.on.ca; dchui at peo.on.ca; rwillson at peo.on.ca; sgupta at peo.on.ca; vkossta at peo.on.ca; rhilton at peo.on.ca;jlee at peo.on.ca; mirwin at peo.on.ca; croney at peo.on.ca
>> Cc: tarsem.sharma at humber.ca; rshreewastav at peo.on.ca; sreid at peo.on.ca; mstauch at peo.on.ca
>> Sent: Monday, December 30, 2013 2:26:24 PM
>> Subject: Re: Engineering concerns regarding Enbridge's data for Line 9
>>
>> Re Enbridge.
>>
>> Dear Ms Lanteigne,
>>
>> This is a personal response as I have no authority to write to you on behalf of PEO Council, particularly for a matter that has not been considered directly by them. However during my term as President I was actively involved in matters that could have impacted the situation that you address.
>>
>> For many years PEO has been trying to modify our Act to remove a section variously known as the Industrial Exception or the Industrial Exemption (IE). This allows manufacturing and other companies an exemption from complying with our Act as far as engineering done by them in certain areas. Unfortunately initial Regulation was never made spelling out the terms of the IE and corporations have self determined their ideas of IE and the scopes that they say are outside our purview. In the last three years we have worked with Government to close this loophole and we have an Act change approved by the Legislature. Unfortunately with two days to go before proclamation a manufacturers’ association lobbied every MP several times such that a cabinet meeting was called at short notice and the proclamation was put on hold. ALL POLITICAL PARTIES were involved in this and none were prepared to stand up against the manufacturers. Since then the manufacturers have been lobbying to have our changes cancelled completely. So unfortunately our employee, Mr. Slack was correct in that we have no apparent jurisdiction over Enbridge.
>>
>> In any event PEO has control over Engineers. NOT over engineering. We licence engineers and can only investigate the performance of (an) engineer(s). We cannot examine the results of their work, just the means by which the work was done. A recent example was the partial mall collapse at Elliot Lake where PEO could not examine or investigate the actual site or the cause of the problem, merely whether any of the several engineers involved over the many years had acted improperly or against our Act as needed to be proven to us by paperwork, etc..
>>
>> Whilst I was PEO President I made an approach to then-Premier McGinty suggesting that Ontario needed an Authority to make investigations and take considerations further than PEO could. We need someone with the authority to investigate the actual engineering and my suggestion, which seems to have been well received by all parties, is that Ontario should appoint a Provincial Engineer answerable directly to the government, perhaps through the Cabinet Office. This would enable considerations before doubtful steps were taken and before the Province got committed to things that might not have long term practical benefits despite perhaps having short term political benefits. I am running for re-election at PEO so that I can pursue this through Council and with the Government. It will be several months before the Elliott Lake Inquiry gives it’s conclusions and although initial mention was made of a Provincial Engineer by the Inquiry I don’t anticipate Government to take action on this quickly unless so instructed by the Inquiry.
>>
>> There are avenues through which you could gain more discussion on this such as OSPE and OCEPP, but as noted above PEO and others are quite helpless unless the Province takes action. I will ask for this item to be brought before Council at the earliest opportunity, which is February.
>>
>> I appreciate your efforts and, on a personal basis, share your concerns. I would appreciate if you could share, with me at least, the timetable of any construction or design review deadlines and any urgencies.
>>
>> Denis Dixon, P.Eng. FEC.
>>
>>
>>
>> ----- Original Message -----
>> From: Louisette Lanteigne
>> To: abergeron at peo.on.ca ; ddixon at peo.on.ca ; daveadams at wightman.ca ; thomas.chong at rogers.com ; sausma at peo.on.ca ;huangr at bennettjones.com ; ibhatia at peo.on.ca ; michael at wesa.peo.on.ca ; rafraser at uwaterloo.ca ; bdony at peo.on.ca ; rjones at peo.on.ca ;ctaylor at peo.on.ca ; dbrown at peo.on.ca ; carlos.qc9z at ncf.ca ; csadr at peo.on.ca ; lking at peo.on.ca ; ekuczera at peo.on.ca ; dchui at peo.on.ca ;rwillson at peo.on.ca ; sgupta at peo.on.ca ; vkossta at peo.on.ca ; rhilton at peo.on.ca ; jlee at peo.on.ca ; mirwin at peo.on.ca ; croney at peo.on.ca
>> Cc: tarsem.sharma at humber.ca ; rshreewastav at peo.on.ca ; sreid at peo.on.ca ; mstauch at peo.on.ca
>> Sent: Monday, December 30, 2013 1:03 PM
>> Subject: Fw: Engineering concerns regarding Enbridge's data for Line 9
>>
>> Dear Members of the Board of Professonal Engineers Ontario
>>
>> I am writing this to request that the PEO review the engineering data being used to support the Enbridge Line 9 pipeline reversal. I have no doubt this projects poses one of the highest engineering risks ever faced by the Province of Ontario.
>>
>> As a delegate I was shocked to witness how Enbridge narrowed the scope of review to exclude significant evidence indicating how this pipeline will rupture if approved as planned. There is evidence taken from Enbridge that reveals the pipeline will rupture in several areas if flow exceeds 740 psi due to the presence of numerous crack clusters, features and corrosion. I tried previously to submit my concerns to the PEO but the request was declined by Mr. Ken Slack, Manager of Complaints and Investigations Regulatory Compliance. He provided me with the letter in the attachment and returned all my written data.
>>
>> I am informing you all directly in good faith, to see if this matter can be reconsidered. I only desire the chance to help relay the concern in order to prevent the risks.
>>
>> Please review the following email and attachment that I have shared with provincial officials as of this morning. It goes into more details of the concerns.
>>
>> Thank you kindly for your time.
>>
>> Louisette Lanteigne
>> 700 Star Flower Ave.
>> Waterloo Ont.
>> N2V 2L2
>>
>>
>>
>>
>>
>> ----- Forwarded Message -----
>> From: Louisette Lanteigne <butterflybluelu at rogers.com>
>> To: "kwynne.mpp at liberal.ola.org" <kwynne.mpp at liberal.ola.org>; "dzimmer.mpp.co at liberal.ola.org" <dzimmer.mpp.co at liberal.ola.org>; "jbradley.mpp.co at liberal.ola.org" <jbradley.mpp.co at liberal.ola.org>; "ahorwath-co at ndp.on.ca" <ahorwath-co at ndp.on.ca>; "jgerretsen.mpp at liberal.ola.org" <jgerretsen.mpp at liberal.ola.org>; "ehoskins.mpp at liberal.ola.org" <ehoskins.mpp at liberal.ola.org>; "ljeffrey.mpp.co at liberal.ola.org" <ljeffrey.mpp.co at liberal.ola.org>; "cfife-co at ndp.on.ca" <cfife-co at ndp.on.ca>; "gmurray.mpp at liberal.ola.org" <gmurray.mpp at liberal.ola.org>; "dorazietti.mpp at liberal.ola.org" <dorazietti.mpp at liberal.ola.org>; "csousa.mpp.co at liberal.ola.org" <csousa.mpp.co at liberal.ola.org>; "dmatthews.mpp at liberal.ola.org" <dmatthews.mpp at liberal.ola.org>; "kslack at peo.on.ca" <kslack at peo.on.ca>; "stephane.dion at parl.gc.ca" <stephane.dion at parl.gc.ca>; "linda.duncan at parl.gc.ca" <linda.duncan at parl.gc.ca>
>> Sent: Monday, December 30, 2013 11:40:13 AM
>> Subject: Engineering concerns regarding Enbridge's data for Line 9
>>
>> Dear Hon. Ministers, and Mr. Slack
>>
>> My name is Louisette Lanteigne and I was a delegate at the National Energy Board hearings regarding Enbridge Line 9 pipeline reversal.
>>
>> After the hearing took place I submitted a written complaint to Professional Engineers Ontario (PEO) that was received on November 4, 2013. The request was intended to facilitate are review of the Environmental Assessment data being used for the approval of Enbridge Line 9 pipeline reversal because the scope of the review was unreasonably limited and significant risks exists that could result in catastrophic ruptures of the pipeline if approved.
>>
>> The data I submitted was presented at the NEB hearing. The concerns voiced to the PEO were specific to structural integrity issues of the pipeline and engineering data submitted as sworn evidence.
>>
>> In response, I received a letter as seen in the attachment, sent on December 19 2013 from Ken Slack, P.Eng Manager, Complaints and Investigations Regulatory Compliance which states the following:
>>
>> "PEO has no record of Enbridge Pipelines Inc. as being a holder of a Certificate of Authorization issued by PEO. Subsequently, this firm does not fall within our regulatory jurisdiction. As a result, PEO cannot process this complaint and your materials are being returned to you hearin."
>>
>> I find the response of the PEO to be insufficient. It appears that discretionary powers are being used to negate a reasonable review of this matter opening up the province to significant economic and environmental risk.
>>
>> Here is the weblink to Enbridge's Engineering Standards and Specifications.
>> http://www.enbridgetechnology.com/Products/Engineering-Standards-and-Specifications.aspx
>>
>> Here is a list of Engineering jobs with Enbridge
>> http://jobs.enbridge.com/careers/engineering-jobs
>>
>> Enbridge is a member of the American Society of Mechanical Engineers
>> http://www.enbridgetechnology.com/About.aspx
>>
>> Under what logic can the PEO or the Province reasonably exclude an assessment of engineering concerns specific to the activities of Enbridge when clearly there is no plausible deniability that Enbridge is providing engineering services in Ontario.
>>
>> PEO's mandate, as described in the Professional Engineers Act, R.S.O. 1990, CHAPTER P.28 is to ensure that the public is protected and that individuals and companies providing engineering services uphold a strict code of professional ethics and conduct.
>> PEO protects and serves the public by:
>> -Ensuring ALL licensed professional engineers are qualified - and by licensing all who qualify;
>> -disciplining professional engineers found guilty of professional misconduct;
>> -taking action against unlicensed individuals who illegally describe themselves as engineers. Similarly, the association can prosecute companies or entities who illegally provide engineering services to the public;
>> -investigating all complaints brought to it about unlicensed, unprofessional, inadequate or incompetent engineering services;
>> -conducting dispute resolution and hearings; and
>> -prepairing performancce guidelines as benchmarks for quality of service in the engineering profession.
>>
>> The passage was taken from the PEO's website at: http://www.peo.on.ca/index.php/ci_id/1801/la_id/1.htm
>>
>> It would seem prudent that the Province facilitate a reasonable review of the engineering work being used to support the Enbridge Line 9 reversal project due to the fact Enbridge limited the scope of the review to the area of their pumping stations which only makes up 2% of the entire length of Line 9. It is not logical to exclude 98% of the pipeline's length from the review process but that is what happened. Enbridge limited the scope of study using discretionary powers leaving Ontario vulnerable for the potential consequences.
>>
>> According to Enbridge's own data, there are several areas of crack clusters and corrosion that will rupture if the system is run at 740 psi or lower yet Enbridge is requesting the transportation of diluted bitumen at 1000 psi without conducting hydrostatic testing. That's not reasonable.
>>
>> The highest pressure the pipe ever ran at was 666 psi in Cardinal Ontario for a total duration of 5 minutes. It has never been run higher. A reasonable engineer would test the entire length at 1500 psi if the system is to run at 1000 psi. Seeing that Taxpayers rely on the PEO to protect the public interest it would seem reasonable to me that the PEO should be involved to some extent, if only to review if Enbridge' proposal is actually up to code.
>>
>> The data supporting this project, or lack thereof, is in my view a National Security Risk that could adversely impact public health, economic and ecological concerns. Potential impacts exists along municipal water intakes along the Grand River. It could contaminate the Great Lakes within hours hurting municipalities, tourism, fisheries in some of the most highly populated areas of Canada.
>>
>> The pipeline is only buried one meter down. It's well over 30 years old and Enbridge admits in writing they only inspect pipelines crossing tributaries once ever 5 years. This is not reasonable. We can do better than this. We must if we are to protect the public interest.
>>
>> What provincial agency or official is responsible to address such concerns if it's not the PEO? Please inform me in writing so I can provide them with my written information.
>>
>> Thank you kindly for your time.
>>
>> Louisette Lanteigne
>> 700 Star Flower Ave.
>> Waterloo Ont.
>> N2V 2L2
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