Dynamic Risk’s Line 5 Alternatives Study:
The Oil Industry’s View of Protecting the Great Lakes
Background on why Gov. Snyder and Attorney General
Schuette should decide that the risk of an oil spill is
The Dynamic Risk study neglects to provide the state with an
independent, fair analysis of the alternatives to Line 5.
Dynamic Risk’s study does not provide a credible worst-case
scenario spill and cost analysis and grossly underestimates
the impact on Michigan of a Line 5 spill.
Dynamic Risk’s study fails to analyze existing pipeline
infrastructure as an alternative to Line 5 in the Straits of
Dynamic Risk’s study overestimates the impact on propane
supply of decommissioning Line 5.
Dynamic Risk wants a tunnel in the Straits of Mackinac.
Cost of A Straits Tunnel: Two Years of Massive Disruption to
Tourism; Emmet, Cheboygan, Mackinac Counties; and Tribal
The Study’s Authors and Enbridge: Oil Industry Friends.
How much risk is acceptable when it comes to an oil spill in the Great Lakes? When it comes to the aging Line 5 oil pipelines in the Mackinac Straits, the State of Michigan now must decide.
Even oil industry firm Dynamic Risk, which in late June produced a state-commissioned report on alternatives to Line 5 embraced by Enbridge and panned by Great Lakes advocates as blatantly biased and flawed, says that the prospect of a Line 5 spill in the Straits is very real.
Dynamic Risk’s analysis concludes there is a 1-in-60 chance of a Line 5 oil spill in the Straits of Mackinac by 2053, when Line 5 turns 100 years old. And independent experts think a Line 5 disaster is even more likely given its age and deteriorating condition. While we don’t know the exact odds, we do know that a 1-in-60 chance of an oil spill in the Great Lakes not acceptable.
The state of Michigan has a duty to protect the Great Lakes, which provide drinking water for half of all Michigan residents and define our way of life. There’s no reason for Gov. Snyder and Attorney General Schuette to keep delaying action to decommission Line 5.
The underlying assumption in Dynamic Risk’s study is if Enbridge says it can sell 23 million gallons of oil that is now being transported daily through Line 5, then it is Michigan’s responsibility to figure out how the private Canadian company can continue to do that. That is a false assumption. So let’s set aside Enbridge’s profits for a minute and focus on Michigan.
It is the State of Michigan’s responsibility to protect the Great Lakes from a Line 5 oil spill, and the report’s Alternative #6— decommissioning Line 5 in the Straits—would do just that (and in the process, create 2,000 construction jobs). According to Dynamic Risk, the impact of eliminating Line 5 oil in Michigan would be tiny—about a two-cent a gallon increase in the price of gasoline. That’s because the vast majority of Line 5 oil goes to refineries in Sarnia, Ontario.
What about liquefied natural gas that is transported through Line 5? According to Dynamic Risk less than 5% of LNGs are transported to Rapid River in the Upper Peninsula for conversion to propane. The remaining 95% goes to Sarnia. The amount going to the U.P. is so modest that it could be supplied by installing a new 4-inch pipeline from Superior, Wisconsin, to Rapid River.
The Dynamic Risk Study: Deeply Flawed and Not Credible
2. The Dynamic Risk study neglects to provide the state with an independent, fair analysis of the alternatives to Line 5.
The report, authored by oil industry firms with business ties to Enbridge, is biased. It promotes building new oil infrastructure in the Straits of Mackinac that would allow Enbridge to continue transporting oil in the Great Lakes when there are other, reasonable alternatives. The Michigan Petroleum Pipeline Task Force called for an alternatives study that was “wholly independent from any influence by Enbridge.” Dynamic Risk and other study contractors have worked for Enbridge, and they are in the business of supporting and building oil and gas pipeline infrastructure. Those businesses depend on companies like Enbridge to keep operating. They should not have been put in charge of a study whose results are tilted toward Enbridge and building new pipeline infrastructure in the Straits of Mackinac.
3. Dynamic Risk’s study does not provide a credible worst-case scenario spill and cost analysis, and grossly underestimates the impact on Michigan of a Line 5 spill.
When the State of Michigan, at the 11th hour, fired another oil industry contractor doing a major risk evaluation of a Line 5 oil spill it was left solely to Dynamic Risk to provide a credible worst-case oil spill analysis. This was a specific requirement of its work agreement with the state. Instead, Dynamic Risk uses assumptions of risk and an averaging model of all oil spills that are not credible. It estimates that:
- Only 20-miles of shoreline would be impacted by a spill. This is
3% of the 720-mile area the University of Michigan found
vulnerable to a spill in its 2016 study.
- An oil spill would cost $100 to $200 million even though Enbridge’s cleanup costs of its Kalamazoo River Line 6B pipeline oil spill in 2010 cost more than $1.2 billion.
4. Dynamic Risk’s study fails to analyze existing pipeline infrastructure as an alternative to Line 5 in the Straits of Mackinac.
This was a requirement of Dynamic Risk’s work agreement with the state and was an essential recommendation from the Michigan Petroleum Pipeline Task Force. Yet Dynamic Risk says it made an early decision to eliminate from its study a comprehensive analysis of transporting Line 5 oil through other existing pipelines, a decision that skewed study results. It failed to even consider the fact that Enbridge’s Line 6B capacity was doubled after Enbridge’ massive 2010 oil spill.
5. Dynamic Risk’s study overestimates the impact on propane supply of decommissioning Line 5.
What we know from Dynamic Risk’s study is that data provided by Enbridge says more than 95% of liquefied natural gas transported in Line 5 goes to Sarnia, Ontario. Less than 5% stays in Rapid River in the Upper Peninsula for processing into propane. Yet the flawed report finds that up to 35 railcars per week or 15 truckloads per day would be necessary to transport propane in the UP. A different, independent study found it would take only one railcar or 3 - 4 truckloads per day to replace Line 5 propane supply to the U.P. and the study admits that it would only take installation of a 4-inch pipeline to continue supplying liquefied natural gas to the Rapid River processing facility.
6. Dynamic Risk wants a tunnel in the Straits of Mackinac .
In its April 2016 proposal to the state, Dynamic Risk expressed enthusiasm for the idea of putting a tunnel through the Straits of Mackinac, a project that could potentially benefit oil industry contractors and consultants like Dynamic Risk. Dynamic Risk’s alternatives study delivers on that enthusiasm with a projected cost estimate for a tunnel that is much lower than other estimates for this type of infrastructure. Dynamic Risk would have us believe that constructing a tunnel would cost $50 million less than decommissioning Line 5. At the same time, they admit they did not have the site-specific information about the underlying rock formations to determine the conditions and depth for the tunnel. Of course underground oil pipelines still rupture and a tunnel would still leave the Great Lakes vulnerable to oil spills, including other portions of Line 5 along the Lake Michigan and its tributaries.
7. Cost of A Straits Tunnel: Two Years of Massive Disruption to Tourism, Emmet, Cheboygan, Mackinac Counties and Tribal Fishing
Tourists visiting the tip of Michigan’s mitt and permanent residents would find their lives, communities and economies unnecessarily upended for more than two years because of massive tunnel construction, including drilling and blasting, that will impact everything from air pollution to traffic congestion to police, fire and medical services. At each end of the tunnel up to 7 acres of land would be set up as a construction and staging area, potentially impacting local parks. Seasonal workers and construction workers would compete for limited rental housing; during the lengthy construction period and everyone in three northern Michigan counties would experience a steady stream of 18-wheel trucks hauling massive amounts of rock and soil excavated to make room for a proposed 30-inch pipeline. Dynamic Risk, which admits all of this in its report, predicts police and medical services “could be stretched beyond their limits.” Moreover, the Straits are, by treaty, fishing grounds for native tribes in Michigan and would likely see large areas impacted by the construction project.
8. The Study’s Authors and Enbridge: Oil Industry Friends
Enbridge paid for the $3.5 million alternatives and risk analysis and serves alongside Marathon Petroleum on a board that is advising Gov. Snyder about Line 5. But Enbridge’s reach goes beyond paying for studies that are supposed to determine the fate of the Great Lakes. Instead of turning to one of the state’s university to lead the study, officials chose Dynamic Risk even though the firm has worked for Enbridge on pipeline projects and is a leading player in the pipeline infrastructure industry. Dynamic Risk worked for Enbridge on the Midwest Sandpiper project and it was recently disclosed that while working on Line 5 studies for the State of Michigan, Dynamic Risk was also working for Enbridge on its Line 3 project in Minnesota. Dynamic Risk also conducted studies for Canadian officials that led to the approval by Quebec authorities of the reversal and expansion of 39- year-old Enbridge Line 9B, which in March 2016 began transporting heavy crude oil from western Canada to Sarnia, Ontario.
Other companies with direct ties to Enbridge are playing key roles in the alternatives study. The Stantec Company, which designs pipelines from engineering to construction, provided design support for the Keystone Pipeline and has been involved in the construction of multiple tunnels. According to Dynamic Risk’s proposal to the state, G.A. Purves, Director of Oil & Gas for Stantec, and a member of the Line 5 Project Team, has provided engineering support for six Enbridge pipeline projects over two construction seasons. Harold Henry, another Line 5 Project Team member for Stantec, was project manager on Enbridge’s Line 4 pipeline expansion. Riyaz Shiyji, Stantec director, provided support for multiple Enbridge projects in Canada.
Kelly Geotechnical Company was selected to participate as a key Line 5 Project Team member while also providing engineering work for Enbridge pipelines in Minnesota and North Dakota on the same Sandpiper project involving Dynamic Risk. In addition, Kelly worked on an Enbridge gas pipeline project in 2015, the Enbridge Northern Gateway Pipeline Project from 2005-2015, and Spectra Energy projects from 2009 to 2011. Enbridge recently merged with Spectra. Line 5 project team member Shane A. Kelly, senior engineer for Kelly, worked in support of two Enbridge pipeline projects and two Spectra Energy projects.
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