October 7, 2019
The United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of the United States and Canada, AFL-CIO (“UA”) respectfully submits these comments in favor of the project in this docket. The UA is an international labor organization representing approximately 355,000 plumbers, pipefitters, sprinkler fitters, service technicians, and welders. The UA includes 17 local union affiliates with over 25,000 active members in Illinois. The UA also includes the state-wide Illinois Pipe Trades Association, headquartered in Springfield.
The facilities the applicants propose to build in Illinois (the “Project”) would allow the Dakota Access Pipeline (“DAPL”) and Energy Transfer Crude Oil Pipeline (“ETCO Pipeline”) (the “Pipelines”) to nearly double in output from 570,000 bpd to 1.1 million bpd, without additional miles of pipeline or physical changes to the Pipelines. In Illinois, the combined cost of the proposed facilities would be approximately $200 million. As such, the Project promises significant socioeconomic, energy efficiency, and safety benefits.
First, this type of project provides important job opportunities for construction workers, including members of the UA and other unions. These are the exact type of skilled jobs–providing good wages, health coverage, retirement security, and training–that are badly needed today. Although pipeline construction jobs are often described as “temporary,” their temporary nature is exactly what makes them so important. Each opportunity for work that is denied is devastating for construction workers who rely on a steady supply of “temporary” projects to provide complete incomes and retirement savings for themselves and their families over their careers. Furthermore, in addition to the construction jobs that would be created, long-term operations and maintenance personnel would be stationed at the new pumping stations. In short, the Project would create jobs, a consideration due significant weight in the Commission’s decision.
In addition, the Project enables the Pipelines to provide the greatest possible benefit in meeting the demand for shipment of crude oil. Current demand for oil transported by the Pipelines exceeds their capacity significantly and is expected to continue to increase. The Project would enable the Pipelines to meet much more of this demand without any structural changes to the pipeline themselves. In essence, the Project enables the Pipelines to meet their full potential.
Finally, the Project promotes safe transportation of oil. While many opposing the Project argue that it stands for an increase in the production of “fossil fuels,” crude oil will be produced whether or not the capacity to transport it by pipeline exists. Where pipeline capacity falls short, the excess oil will be transported by rail and truck, presenting significant safety risks and attendant carbon emissions.
The danger of above-ground transportation of oil should not be underestimated. In just the past several years, Illinois has seen the threat it presents firsthand. In 2015, 21 cars of an oil train derailed near Galena, Illinois where the Galena and Mississippi Rivers meet. Seven of these cars ruptured and 5 caught fire. The train contained 630,000 gallons of crude oil, of which at least 218,000 gallons spilled, threatening contamination of the Mississippi River. In 2017, 20 cars of an oil train derailed in Plainfield, Illinois, spilling 20,000 gallons of crude oil. The primary damage from these derailments was to property and the natural surroundings. But the danger to human life from oil train derailments is also very real. The most chilling example of this danger occurred in 2013, when a 74-car crude oil train derailed in Lac-Mégantic, Quebec and several cars exploded, killing 47 people and spilling 1.5 million gallons of oil.
In contrast, pipelines are the safest, most efficient way to transport oil. The Pipelines are particularly safe as they were built recently with the most up-to-date materials and techniques. Specifically, the Pipelines were built with high-strength carbon steel with thicker walls in sensitive areas and road and water crossings and cathodic protection systems and fusion-bonded epoxy coating to prevent corrosion. They are monitored 24 hours a day at a dedicated operations center and aerial and ground inspection. These safety features mean the oil passing through the Pipelines is transported in the safest way possible. Increasing their capacity is therefore a net positive in terms of safety.
For all these reasons, the Project as proposed is a common sense, efficient solution that maximizes existing pipeline infrastructure, avoids new pipeline construction and modifications to existing pipelines, and reduces the need for trains and trucks to transport oil. The UA urges the Commission to keep these benefits in mind and approve the Project.
David L. Barnett
UA Director of Pipeline and Gas Distribution
David L. Barnett