Leave to Open

Enbridge has filed for “Leave to Open” (LTO) Line 9. This is the final regulatory approval Enbridge needs to start flowing diluted bitumen (oil sands) and/or volatile Bakken crude through the most highly populated region in Canada.

Rather than apply for LTO with a formal announcement, Enbridge broke the application into pieces and quietly applied for final LTO on February 6th, 2015.

Here’s the breakdown on how it happened:

Partial LTO 1 – 05/08/2014 – Series of LTO applications for equipment at the project facilities, including Sarnia A and North Westover A.

Partial LTO 2 – 07/29/2014 – LTO application for Sarnia B

Partial LTO 3 – 08/15/2014 – LTO application for Sarnia C

Partial LTO 4 – 09/04/2014 – LTO application for Sarnia D

Partial LTO 5 – 09/19/2014 – LTO application for Sarnia E

Partial LTO 6 (FINAL) – 02/06/2015 – LTO application for North Westover B, Hilton A, Cardinal A and Montreal A.

The National Energy Board confirmed receipt of the final LTO on 02/13/2015 with a letter response to Enbridge stating the NEB would be filing another information request with questions for Enbridge. As of April 5th, 2015, the NEB has still not submitted this IR.

Keep in mind that the NEB is not requiring Enbridge to conduct a hydrostatic test of the pipeline. This would involve moving water through the pipeline at a slightly higher pressure than the pipe is approved for in order to test the integrity and ensure there are no cracks, corrosion or dents that could result in an oil spill. Enbridge argued in the NEB hearing that a hydrotest would place unnecessary pressure on the pipe.

We know it’s old, we know the pipe tape coating is outdated, we know there are outstanding concerns from communities.

If you have concerns about Line 9, now is the time to write to the National Energy Board. Regardless of whether you were an intervenor, commenter, or did not participate in the regulatory process, Canada is still a democracy and you have every right to be heard!

Here are the instructions on how to submit a letter to the NEB for Line 9 …

1. Go to http://www.neb-one.gc.ca/ and select language

2. Scroll over Applications & Filings, then select Submit Applications and Regulatory Documents

3. Select File a Letter of Comment

4. Select Non-Hearing Section 58

5. The rest of the eight steps are fairly self-explanatory. In Step 2 of 8, select “other” as the project name. Your role in Step 3 of 8 will also be “other”. Step 5 of 8 document type – “other”. Step 6 of 8 – Skip paper documents. Click next in step 7 of 8 (unless of course you want to send a courtesy copy to Enbridge or a government official). Confirm and submit in step 8.

If you have any questions, please email me at line9communities@gmail.com

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