In 2013, TGG was retained by a coalition of Quebec- and Ontario-based environmental groups (the Équiterre Coalition) to provide expert testimony related to a controversial crude oil pipeline: Enbridge’s Line 9B Reversal and Line 9 Capacity Expansion (300,000 barrels per day at full capacity). The project would transport a mix of tar sands dilbit and synthetic crude oil (SCO), Bakken, and conventional Western Canadian crudes through Ontario and Quebec, crossing major waterways and Canada’s most populous urban areas (including Toronto and Montreal). TGG filed written expert testimony entitled, The Relative Economic Costs and Benefits of Enbridge’s Line 9B Reversal and Line 9 Capacity Expansion Project in August 2013 at Canada’s National Energy Board (NEB) on behalf of the Équiterre Coalition.
In the preparation of our testimony, TGG collaborated with international pipeline safety expert Richard Kuprewicz, also retained by the Coalition. TGG used Mr Kuprewicz’s high-risk assessment for rupture of the pipeline as an input for our evaluation of a range of worst-case rupture costs. We demonstrated that due to Line 9B’s extraordinary proximity to people, water and economic activity, the rupture costs of the project (under a wide variety of pipeline accident/spill possibilities) could range from significant to catastrophic. TGG also examined the benefits of the Project. We concluded that the potential economic costs could exceed (and, under a wide range of accident/spill conditions, greatly exceed) the potential economic benefits.
Update: During the NEB review, the project faced significant public opposition in Quebec and Ontario, and significant concerns were expressed by emergency responders, municipal governments and provincial ministries. However, the NEB approved the Line 9B Reversal and Line 9 Capacity Expansion in March 2014 with 30 conditions. Many of these conditions related to pipeline and public safety issues associated with the project. A number of these issues had been raised in TGG’s testimony and identified by pipeline safety expert, Richard Kuprewicz. The flow of Line 9B was reversed starting in December 2015 (over a year after the NEB’s approval with conditions).
The Line 9 proposal was the first major crude oil pipeline reviewed following the Harper Conservative government’s changes to the NEB Act (part of an omnibus bill known as Bill C-38) in 2012. Many Canadian environmentalists and members of civil society strongly opposed Bill C-38. Among the most controversial changes to the NEB Act were the limits placed on public participation in the hearing process. The Line 9 hearings (under the new Act) further eroded public confidence in the impartiality of the NEB. This loss of confidence was exacerbated by a subsequent scandal involving NEB Panel members for the review of Energy East, another major crude oil pipeline.(See also TGG Project Description for Economics of Transporting Tar Sands Crudes in Quebec.) Under Trudeau’s Liberal government, the National Energy Board was dismantled and its energy regulation function was assumed by the Canadian Energy Regulator in August 2019.
Complete TGG Filings
Other Project Products
STRATEGIC/TECHNICAL ADVICE | 2012-2013
CLIENT BRIEFINGS | 2012-2013
SUPPORT TO COUNSEL | 2013
MEDIA INTERVIEWS | Autumn 2013
TV Interview on the Les coulisses du pouvoir, a current affairs program on Radio-Canada (Canada’s national French public broadcaster), September 30, 2013
TV Interview with Andrew Bell on Commodities, a BNN Bloomberg TV program on commodities and their producers, October 22, 2013
ORAL TESTIMONY | December 3, 2013
Provided oral testimony before the Quebec Parliament on the acceptability for Quebec of Enbridge Pipelines Inc. Line 9B Reversal and Line 9 Capacity Expansion Project Proposal before the Canadian National Energy Board
