18 October 2014

Ontario Energy Board
P.O. Box 2319
Toronto, ON, M4P 1E4

Re: Proposed Energy East Pipeline

I am writing to express my deep concern about the proposed Energy East Pipeline and to recommend that you do not approve this project. This pipeline, if approved, would encourage reckless growth in the tar sands, would make climate change worse, would help ensure that Canada does not meet our commitments on climate change, and would put our local ecosystems and drinking water at risk.

Tar sands production is Canada’s fastest-growing source of the carbon pollution that causes climate change. Canada’s tar sands producers intend to more than triple their production to over 5 million barrels per day by 2030.[1] This growth in production is expected to triple tar sands carbon pollution between 2005 and 2020, an increase large enough to cancel out all emission reductions that other parts of Canada’s economy are expected to make over the same period, including Ontario’s phase out of coal.[2] Filling the Energy East Pipeline would result in upstream emissions of about 30 million tonnes, roughly equivalent to doubling the fleet of passenger cars in Ontario.[3] It is clear that Canada will not meet our international commitments on climate change if this reckless growth in tar sands production is allowed to proceed.[4] If the proposed Energy East Pipeline is approved, it will lock in growth in tar sands emissions for decades, help ensure Canada reneges on our international climate change promises and increase climate change risks for all sectors of our society.

Energy East Pipeline proponents may argue that tar sands oil will get to market one way or the other (e.g., via rail or other pipelines), and that building this pipeline will not affect upstream emissions. However, it is clear that tar sands growth is not inevitable and that pipelines matter. For example, in September 2014 Norway’s Statoil shelved a multibillion-dollar tar sands project, blaming rising construction costs and the repeated delays in new export pipelines that would boost the value of Canadian heavy crude oil.[5] Without the low cost transportation provided by pipelines like Energy East, tar sands growth will not be locked in and we have a better chance to manage our carbon pollution.

Building long lived infrastructure to produce or transport tar sands oil is not consistent with a safe climate. Even the former governor of the Bank of Canada, Mark Carney, recognizes that the “vast majority of reserves are unburnable” if global temperature rises are to be limited to below 2°C.[6] Given this reality, it makes sense to leave the dirtiest fossil fuels like tar sands in the ground. Since Canada clearly does not have a strategy or a plan to achieve our GHG emission reduction targets, no new tar sands production or transportation projects should move forward until their cumulative impacts are consistent with our national and international commitments to reduce carbon pollution.[7]

Please consider my concerns in your review of the Energy East Pipeline, and keep me informed of your review process for this project so that I can participate in this process.

Sincerely,

Duncan Noble

[1] Canadian Association of Petroleum Producers (CAPP), June 2014: Crude Oil Forecast, Markets and Transportation

[2] Environment Canada, 2013: Canada’s Emissions Trends (2013)

[3] Pembina Institute, 2014: Climate Implications of the Proposed Energy East Pipeline: A Preliminary Assessment

[4] Auditor General of Canada, 2014: Report of the Commissioner of the Environment and Sustainable Development

[5] Globe and Mail, September 26, 2014: “Statoil halts multibillion-dollar Alberta oil sands project”

[6] The Guardian, October 13, 2014: “Mark Carney: most fossil fuel reserves can’t be burned”

[7] Palen et al., Nature (25 June 2014): Energy: Consider the global impacts of oil pipelines