[All] Fw: We need updated information re: Enbridge Insurance coverage
Lanteigne
water.lulu at yahoo.ca
Wed Jan 29 16:18:35 EST 2020
FYI
Louisette Lanteigne700 Star Flower Ave.Waterloo OntN2V 2L2
----- Forwarded Message ----- From: Lanteigne <water.lulu at yahoo.ca>To: Jacqueline.Vanhouche at cer-rec.gc.ca <jacqueline.vanhouche at cer-rec.gc.ca>Cc: Justin Trudeau <justin.trudeau at parl.gc.ca>; chrystia.freeland at parl.gc.ca <chrystia.freeland at parl.gc.ca>; Seamus.ORegan at parl.gc.ca <seamus.oregan at parl.gc.ca>Sent: Wednesday, January 29, 2020, 05:13:36 p.m. ASTSubject: We need updated information re: Enbridge Insurance coverage
Dear Hon. Prime Ministers et al.
I reviewed in detail the response of Mr. Peter Watson of CER today and it's mind boggling the lack of fiscal and judicial prudence I am observing with how Enbridge's liability issues are being addressed.
Mr. Watson provided me with a URL that dates back to a funding plan rooted in 2016. It identifies Enbridge's assets as well as the fiscal structure and it's woefully out of date.
Please visit this link as provided to me by Mr. Watson in the email response he sent. I include the full email in the attachments.This is the link he referenced:
https://apps.cer-rec.gc.ca/REGDOCS/Item/View/2955535
So visit that site and click on Form A76389 which will bring you to a new webpage featuring A76389-A.
So looking at A76389-A you will see one of the assets identified here is Enbridge Line 10. That is a pipeline linked to 74,000 bpd worth of product. The problem is Enbridge no longer owns it. This pipe was just sold to Westover Express.
I provided written comments in regards to the sale of the Line 10 pipeline. I can testify to the fact that First Nations open houses were conducted before this purchasing company even existed and there was no further public open houses after it was incorporated on March 26, 2018. Westover Express is a shell company with no assets or liability working out of BC as an entity wholly owned by a US based company called United Refining Co. which is owned by Trump supporter John Catsimatidis. They basically slid over Canadian MLP tax free formula to benefit a US based entity and this was without any formal hearing whatsoever. The decision is online here given just a few months away from the date of Westover's incorporation. Apparently it is very easy now for a brand new company backed by foreign ownership to simply purchase a high pressure oil pipeline now.
https://docs2.cer-rec.gc.ca/ll-eng/llisapi.dll/fetch/2000/90464/90552/3563446/3562780/3777908/A99283-1_Letter_Decision%2C_MO-014-2019_and_MO-015-2019_to_Enbridge_Pipelines_Inc._and_Westover_Express_Pipeline_Limited_%E2%80%93_Sale_and_Purchase_of_Line_10_-_A6U2K2.pdf?nodeid=3777909&vernum=-2
As for the assets of Enbridge Pipelines (Westspur) Inc that was sold off to Tundra Energy Marketing Limited ("TEML") for $1.075 billion in cash.on Dec. 2016. The press release from Enbridge is here to support this: https://www.enbridge.com/media-center/news/details?id=122522&lang=en
You can see a long list of pipelines under the name Enbridge PIpeline Inc. which includes lines 1 through 67 but this has no regard to the fact that
Enbridge Pipeline Inc sold these assets to Enbridge Income Fund Holdings Limited. I was interviewed by the National Observer about the sale of those pipes and I was worried because they switched the ownership as the hydrostatic and integrity testing was still taking place on Line 9. Here is the article making note of the concerns.
https://www.nationalobserver.com/2015/08/20/news/controversial-pipeline-changing-hands
Now visit this link again https://apps.cer-rec.gc.ca/REGDOCS/Item/View/2955535 and look at A77040 and open that up and you will see the funding model for the insurance references Enbridge Income Fund Holdings Inc.yet today that company no longer EXISTS. This fact is verified by Enbridge here: https://www.enbridgeincomefund.com/ and it clearly states this firm it was aquirred by Enbridge Inc.
So to suggest that Enbridge Pipeline Inc. still ownes the assets of Enbridge Inc. is FALSE. They are by law, TWO SEPARATE COMPANIES.
According to Bloomberg this is the board of Directors for Enbridge Inc and their address is 3000 Fifth Ave Place 425 1st Street SW Calgary, AB T2P 3L8 Canadahttps://www.bloomberg.com/profile/company/ENB:US
According to Bloomberg this is the board of Directors for Enbridge Pipeline Inc. and their address is .200, 5th Avenue Place 425-1st Street Southwest Calgary, AB T2P 3L8 Canada https://www.bloomberg.com/profile/company/1180Z:CN
So why did Mr. Watson send me an out of date response that is no longer factual or relevant regarding the issue of Enbridge's assets and liablity coverage?
Where is the fiscal and judical prudence?
Why doesn't the CER provide current factual data on who owns what asset?
Why doesn't the CER stay on top to make sure that the Ceritificates of Public Needs are current and that the corporate liability information is up to date?
As of December 2019, Enbridge has divested billions of assets and they are still in debt $60.9 billion dollars. https://calgaryherald.com/commodities/energy/how-enbridge-plans-to-grow-in-the-age-of-pipeline-opposition-and-connect-canadian-oil-to-world-markets/wcm/f07fff26-ed3b-4d20-986e-1640bb4a6aff
There are new increased tariff rates issued by the FERC which now applies to these pipelines currently which may change the numbers as well.
https://www.enbridge.com/~/media/Enb/Documents/Tariffs/2019/LKH%20FERC%2045190%20CER%20455%20CDMN.pdf
There are serious concerns in the US, that Enbridge doesn't have proper liability coverage.
“In the event of a catastrophic oil spill, the people of the state of Michigan could be left holding the bag for more than a billion dollars in unfunded liability,” said a statement from Michigan Attorney General Dana Nessel. https://www.mlive.com/news/2019/11/enbridge-could-duck-cleanup-costs-from-future-line-5-spill-study-says.html
The statement was based on this report: An Analysis of The Enbridge Financial Assurances Offered to the State of Michigan On Matters Related To The Operation of The Enbridge Line 5 Pipeline At the Straits of Mackinac Prepared For The State of Michigan The Michigan Department of Attorney General The Michigan Department of Environment, Great Lakes and Energy The Michigan Department of Natural Resources By American Risk Management Resources Network, LLC October 29, 2019
https://www.michigan.gov/documents/ag/Master_Michigan_Enbridge_10_29_final__670367_7.pdf
In light of these concerns, I respectfully request an updated document to prove that Enbridge has 1 billion liability set aside to address oil spills and this time, and please do not rely on naming dead companies and non factual ownership. Let us see the current view because if a spill happens today, we need clarity on the current situation as it stands right now.
The 2016 information as provided by Mr. Watson is no longer logical or relevant. We need to keep critical data like this updated and contractually factual.
I also respectfully request that all the CPCN permits will be updated to reflect the contractual obligation of the current pipeline owners.This is to protect all the workers working on those lines in compliance to labour laws and regulatory procedures. It is needed to facilitate lawful engineering work, maintenance and protection of workers, the communities, investors and the public interest. This is not an unreasonable request. This is the law as it was designed.
Why is it that the CER does not appear to be working in compliance to the law right now. We can't go on like this.
Please send me the updated information please.
Thank you kindly for your response and I pray you will provide me with the update information in good faith.
Yours sincerely
Louisette Lanteigne - Concerned Citizen700 Star Flower Ave.Waterloo ONN2V 2L2
On Wednesday, January 29, 2020, 11:30:02 a.m. AST, Lanteigne <water.lulu at yahoo.ca> wrote:
Dear Hon Prime Minister and Ministers.
Line 9 goes in front of York University, over top Finch Subway Station, it crosses downtown Toronto and it flows upstream of Darlington Nuclear plant.
If a spill happens in any of one of these areas or oil gets into the intake of Darlington or Pickering, one Billion won't reasonably cover the costs of the spill or the associated shut down of York University, Finch Subway Station, lost property values in Downtown Toronto or a lengthy shut down of a nuclear plant.
The pipeline is at end of life. This infrastructure is a public risk and in my view a National Security issue. We lack the proper safeguards to reasonably address these risks and we lack reasonable liability coverage.
Who at this point in time, has the legal contractual obligation here? Who's name is literally on the CPCN certificate? If a damn piece of paper can protect us better, my advice is that we need to take the time and effort to get that writing down and signed. We need the legal names recorded that the people who own it are unquestionably contractually obligated to cover the total costs. It's their corporate risk not ours to assume. They want to work with Canada make them assume their own liability risks.
Louisette Lanteigne700 Star Flower Ave. Waterloo Ont.N2V 2L2.
Sent from Yahoo Mail on Android
On Wed., 29 Jan. 2020 at 9:30 a.m., Jacqueline Vanhouche<Jacqueline.Vanhouche at cer-rec.gc.ca> wrote:
Good morning,
Please find attached a letter from Peter Watson, Chief Executive Officer of the Canada Energy Regulator.
Please feel free to contact me should you have any questions.
Best regards,
Jacqueline Vanhouche
Executive Assistant to the CEO / Adjointe exécutive au président-directeur général
Executive Office / Bureau de la direction
Tel.: 403-299-2725 / Tél.: 403-299-2725
Email / Courriel: Jacqueline.Vanhouche at cer-rec.gc.ca
Suite 210, 517 Tenth Avenue SW, Calgary, Alberta T2R 0A8
517, Dixième Avenue S.-O., bureau 210, Calgary (Alberta) T2R 0A8
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