[All] Line 9 Leave to Open: THE REST of the story...

[Louisette Lanteigne]

Hi folks
Here is the NEB has added new conditions to the Line 9 approval process as seen here at https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/fetch/2000/90464/90552/92263/790736/890819/2432299/2680267/Letter_and_Order_MO-001-2015_-_A4H2Z0.pdf?nodeid=2679828&vernum=-2
Page 3 it states: Condition 18 requires submission of a WCMP (Water Course Management Plan)  priorto a Leave to Open application, and condition 25 requires an update in the year following.Conditions 18 and 25 also require Enbridge to incorporate the existing conditions as a newbaseline in its Environmental Protection Program, a Program required to anticipate, prevent,manage and mitigate conditions that could adversely affect the environment.
During my Line 9 presentation I spoke of how in Ontario, we see trends of flood year drought year cycles associated with Climate Change. This is why they need at least two years of monitoring to determine the risks associated with heavy precipitation events. Shouldn't set the baseline using only drought year data. It's good to see this year to year study happening. 
Go to page 4 of the report. It states: 
Enbridge must apply for and be grantedLeave to Open. 
In otherwords, that process isn't done yet.  It takes 90 days for the NEB to make it's decision regarding Leave to Open and the application has not even been submitted yet. 
The Board reminds Enbridge that, in addition to complying with all its owncommitments made during this proceeding, Enbridge must comply with all Post Constructionconditions in the 2014 Order.
In otherwords the process is to date: incomplete.
In order for the Board to consider and assess the ongoing valve placement needs in this specificarea through the lifecycle of the pipeline, the Board requires further information from Enbridge.Accordingly, pursuant to subsection 48(1.1) of the National Energy Board Act and section 6 ofthe National Energy Board Onshore Pipeline Regulations, the Board has issued the attached2015 Order. The 2015 Order will facilitate and require ongoing review and analysis of watercrossings, valve locations and associated risks in accordance with Enbridge’s IVP methodologyto ensure that Line 9 continues to protect public safety and the environment throughout itslifecycle.

At the hearing I raised concerns that the placement of the valves  along the Grand River in Waterloo Region had little to no regard for Climate Change impacts or for post development growth upstream. The bigger the cities upstream groups, the more storm water flows down the river which creates erosion issues and wider channels. The valve by the Grand River in Waterloo Region may have been a reasonable placement when it was first installled but it ended up placed in the middle of a flood plain so if the pipe ruptured during a flood, someone would have had to go into the water to shut off this manual valve.  Enbridge has since moved the valve to a different location. The new conditions are demanding that Enbridge review the placement of the valves to have regard for the full life cycle of the pipeline.  Technically, this may mean they HAVE TO HAVE REGARD FOR CLIMATE CHANGE IMPACTS in terms of water flow, flow rates and flood risks. 

Now in reading the news I found this article in the Globe and Mail that suggests Line 9 will be used to carry US and Canadian oil. This is news to me because in all the regulatory documents it is described as a "common carrier" aka domestic oil for domestic use. There has been no permissions granted to allow for that transition.  In light of that concern I've written to the Secretary of the NEB and a few ministers to keep them in the loop on this. 
I'll notify you if I get any responses. 
Lulu 
----- Forwarded Message -----
From: Louisette Lanteigne <butterflybluelu at rogers.com>
To: "secretary at neb-one.gc.ca" <secretary at neb-one.gc.ca>; "justin.trudeau at parl.gc.ca" <justin.trudeau at parl.gc.ca>; "pm at pm.gc.ca" <pm at pm.gc.ca>; "thomas.mulcair at parl.gc.ca" <thomas.mulcair at parl.gc.ca>; "Elizabeth.May at parl.gc.ca" <Elizabeth.May at parl.gc.ca> 
Sent: Saturday, February 7, 2015 10:20 PM
Subject: Article suggests Line 9 is NOT intended as a simply a common carrier.

I was observing this article as published today by the Globe and Mail titled: NEB approves Enbridge's LIne 9 with revised safety plan by Shan McCarthy and Jeff Lewis. 
In the article is states the following passage:  
Enbridge spokesman Graham White said the company supports the safety and operating conditions imposed by the regulator, and will fulfill them. It expects the mixture of light crude from Canada and the U.S. will begin flowing to Quebec refineries by this spring. http://www.theglobeandmail.com/report-on-business/industry-news/energy-and-resources/neb-approves-enbridges-revised-line-9-safety-plan/article22829868/

As a delegate at both Line 9 hearings I can vouch for the fact this line was approved as a common carrier pipeline aka: Domestic oil for domestic use.  I do not recall requests being made at all to transport US oil.  If the function is to move US and Canadian oil it is not technically not a common carrier.
Can I please have some clarity on this issue? Does the line fit the common carrier status if it is being used to move US oil too?
Has Enbridge applied for permissions to move US product?
>From where is this US oil coming? 
Thank you kindly for your time.
Louisette Lanteigne700 Star Flower Ave.Waterloo Ont.N2V 2L2






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