Enbridge says it operates the largest, longest, and most complex petroleum pipeline system in the world: approximately 25,420 kilometers (15,795 miles) of pipe delivers an average of more than 2.2-million barrels per day of crude oil and liquids. The Enbridge Mainline system is the largest conduit of oil into the United States. Enbridge transports 53% of US-bound Canadian production, a figure that accounts for approximately 15% of total US crude oil imports.

The existing Mainline system into the US constitutes four primary pipelines (Lines 1, 2, 3 and 4) as well as related lines, including Line 67—the Alberta Clipper.

Enbridge US Mainline West as of August 2014. Click to enlarge.

In 2009, the State Department issued a Presidential Permit authorizing the construction, operation and maintenance of the 36-inch diameter Line 67 pipeline extending between the US-Canada border near Neche, ND and the first US mainline shut off valve or pumping station in the United States. (Earlier post.)

That near-border segment of the Pipeline authorized by the 2009 Permit is only 3-miles long. Enbridge constructed the remainder of the Line 67 Pipeline in the United States to its southern terminus at Superior, Wisconsin, pursuant to other local, state and federal permits. Enbridge completed construction and began operations of Line 67 (Alberta Clipper) in 2010; the pipeline currently transports an average annual capacity of approximately 495,000 bpd of crude oil across the border.

In 2012, Enbridge requested that the US Department of State issue a new Presidential Permit to authorize Enbridge to operate the border segment of its existing Line 67 crude oil pipeline up to its full design capacity. Full design capacity for Line 67 is 880,000 bpd for heavy crude. (This will vary based on the type of product transported. For example, the full design capacity of Line 67 would be greater than 880,000 bpd were light crudes transported on the line, which could be case in the future, the company noted.)

However, the permitting process did not proceed as smoothly or quickly as Enbridge had planned. Hence, in a 16 June 2014 letter to the State Department, law firm Steptoe & Johnson explained that:

… shipper needs dictate that the annual average capacity of Line 67 in the United States be increased up to 570,000 bpd by mid-2014 (referred to as “Phase I”), and up to 800,000 bpd by mid-2015 (referred to as “Phase II”). As we explained, the unforeseen Line 67 Project permitting delay at the Department of over a year has led Enbridge to recently assess options for achieving this additional capacity both at the border, albeit not on Line 67, and on the portion of Line 67 south of the border segment, consistent with Enbridge’s obligations as a common carrier pipeline operator and its existing Presidential Permits.

… To avoid adverse impacts to shippers of the sort described by the ALJ [Administrative Law Judge], Enbridge has decided to optimize its existing Mainline System to provide the flexibility and efficiency that it would need to transport increased volumes of crude oil from Canada into the United States within the terms of its existing Presidential Permits, as explained below.

The basic plan is to build interconnections between Line 67 and the adjacent Line 3 to give Enbridge the capability to increase the volume of crude oil. The increased flow will:

1. Move on Line 67 in Canada towards the border;

2. be transferred to Line 3 at Enbridge’s Gretna, Manitoba station at a point approximately 1.5 miles (2.4 km) north of the US-Canada border;

3. cross the US-Canada border on the Line 3 border segment; and

4. then be transferred back to Line 67 approximately 16 miles (25.7 km) south of the US-Canada border for delivery to Superior.

Enbridge is planning four interconnections between Lines 3 and 67 as part of this project. Two interconnections will be constructed between Line 67 and Line 3 at the Gretna station in Canada to allow crude oil to move between the lines north of the border crossing; and two interconnections will be constructed between Line 67 and Line 3 in the United States to allow crude oil to move between the lines at a point in North Dakota about 16 miles south of the border, which is south of the first US mainline valve for each line.

From Enbridge Exhibit B as published by the US State Department. The red lines show the connections between the Alberta Clipper and Line 3. The dotted lines show future connections. Mileposts are relative to Edmonton. Click to enlarge.

Enbridge envisions possible future interconnections between Line 3 and Line 4.

The construction and operation of the US interconnections does not require any federal, state, and/or local approvals, the company said. The Canadian interconnections will be constructed within the boundaries of Enbridge’s existing Gretna station; Canadian approvals have already been obtained.

The company also has Canadian approval to transport increased volumes of crude oil on Line 67 in Canada up to 800,000 bpd. Enbridge is currently constructing the pump upgrades in Canada to allow for an increase in the authorized capacity of the line in that country. Once construction of those pump upgrades is complete, which is expected in the coming weeks, Enbridge will have the operational flexibility to flow an increased amount of oil on Line 67 in Canada to the Line 3 border segment for transportation across the US-Canada border.

Enbridge said it has also obtained all necessary US approvals to transport an average annual capacity of 570,000 bpd on Line 67 south of the Line 3 interconnection and plans to do so.

Enbridge has already received approval for and has begun construction of a pump upgrade in Minnesota to support 570,000 bpd. However:

… unless and until the Department issues the requested Presidential Permit allowing Enbridge to transport more than 500,000 bpd across the border on Line 67, the interconnections will actually result in a decrease of 105,000 bpd of crude oil across the Line 67 border segment (from the current 495,000 bpd of heavy crude to 390,000 bpd of light crude), and an increase of 180,000 bpd of crude oil (from 390,000 bpd of light crude to 570,000 bpd of heavy crude) across the Line 3 border segment. These cross-border volumes are compliant with the currently applicable Presidential Permits for both lines.

The pipeline interconnections thus provide Enbridge with the operational flexibility to transport crude oil in the range of 800,000 bpd of oil on Line 67 south of the Line 3 interconnection through the construction and operation of the pump upgrade.

The use of pipeline interconnections is a standard industry practice; multiple interconnections already exist between Enbridge Lines 2, 3, and 4 both in Canada and the United States. Enbridge is also constructing an interconnection between Line 67 and Line 4 at Hardisty in the event of a shutdown of Line 4 between Edmonton and Hardisty.

Enbridge said that it will construct the interconnections and pump upgrades, and to operate those facilities to increase the flow of oil on Line 67 south of border segment, whether or not the requested new Presidential Permit is issued by the State Department.

In other words, the interconnections and Pump Upgrades are not a result (either directly or indirectly) of the Department’s action on Enbridge’s pending application because the Pump Upgrades and interconnections, and any resulting environmental impacts, will occur regardless of whether the Department issues a new Permit to authorize an increased level of flow on the border segment of Line 67.

—Letter to the State Department