Enbridge – Time for an Oil Change

OCTOBER 14, 2014 – Some 300,000 barrels of oil per day, sometime this fall, were to have begun flowing from Sarnia, Ontario to Montreal, Quebec – courtesy of Enbridge “reversing the flow” on its 40-year old “Line 9” Ontario and Quebec pipeline. But a surprise ruling by the National Energy Board (NEB) will delay that flow for a few months (McCarthy 2014).


Line 9 is destined to carry, among other products, diluted heavy crude from the Alberta oil/tar/bitumen fields. A spill of such heavy crude would, of course, be very serious, as the residents of Kalamazoo Michigan well know, who in 2013 were still dealing with the aftermath of a then three-year old 3.3 million litre spill of heavy oil from a ruptured Enbridge pipeline (Paris 2013).

The residents of Kalamazoo learned they had multiple problems. First what spilled was actually “dilbit” – a mixture of diluents and bitumen. The bitumen component – 70% of the material in the pipeline – is very dense, and sank to the bottom of the Kalamazoo River. “Submerged oil is significantly harder to clean up than floating oil”. Equally bad, the other 30 percent – the diluents – are comprised of chemicals mixed with the very thick bitumen so that the mixture will flow through pipelines. “The exact composition of these chemicals … is considered a trade secret. … The mixture often includes benzene, a known human carcinogen” (McGowan, Song, and Hasemyer 2012, “A Dilbit Primer”).

To minimize the damage from a spill, the NEB had asked Enbridge to identify Major Water Crossings (MWCs), and to demonstrate that emergency shut-off valves were in place should a spill occur nearby. This is quite sensible. It is good plumbing practice in everyday life, to install shut off valves next to each fixture (sink, toilet, dishwasher), so that any leak can be quickly contained. The difference in the case of Enbridge, is that an uncontained leak (as in Kalamazoo) will do somewhat more damage than a leaky dishwasher.

At first Enbridge identified just 19 MWCs, a figure we can infer from the information provided in the NEB letter. In response to what is called “Information Request Number One”, Enbridge did agree to add 85 water crossings to its list, bringing the total number of MWCs to 104. However, if it adjusted the list, it “did not adjust the number of valves to the Project … As a result, the Board notes that only 6 of the 104 MWCs identified by Enbridge to date appear to have valves installed within 1 km on both sides of the water crossing, while the majority appear to have valves installed more than 10 km from the water crossing on at least one side” (Young 2014, 2).

Certainly safety valves 10 kilometres from a major water crossing would be ineffective in the face of a major spill. The standards of “within one kilometer” and on both sides of the water crossing are better – but still not all that reassuring. Considerable damage can be done by oil soaking into a watershed one kilometer from the edge of a waterway, major or otherwise.

The NEB sent the corporation back to the drawing board, refusing to grant it permission to start the flow of oil in the reversed Line 9 until Enbridge had addressed this issue. After the company does this and submits a new report back to the NEB, it will then have to wait another 90 days while the NEB studies the submission, and rules as to whether the company has done enough.

This delay of Line 9 is good news for those concerned about the environment. However, the delay is only temporary, and we need to remember that the NEB has been mostly hostile territory for environmentalists challenging corporations like Enbridge. Ruling after ruling has come down on the side of the industry, ignoring or minimizing concerns raised by social movement activists.

In fact, according to one industry insider, this slap on Enbridge’s wrist may actually help the oil industry by giving new credibility to the NEB “and its new chair and CEO, Peter Watson. Delays to Line 9’s in-service date won’t help Canadian crude differentials in the short-term, but in the longer run the NEB’s decision – and the impact it may have on public perception of its autonomy and independence – may be good news for the industry as a whole” (Fawcett 2014).

Mapping the line

As we wait Enbridge’s response and a new ruling from the NEB, we can do our own examination of the topography of the land to be travelled from Sarnia to Montreal, and draw our own conclusions. A helpful tool in this process is the website “Line 9 Communities” created by Emily Ferguson, a recent graduate from McMaster University. She has put in long hours and “compiled satellite images, integrity data and publicly available information to create detailed maps of the 639 km pipeline” (Ferguson 2014), giving us an extremely informative picture of the terrain over which the Line 9 dilbit will be travelling.

A second tool is “The Atlas of Canada – Toporama” (Canada and Natural Resources Canada 2003), which among other information, provides names of rivers, streams and lakes over the area to be traversed by Line 9. By comparing the maps available on the two web sites, a list can be created of the major waterways likely to be crossed by Line 9. The results of that process are available in Table 1, appended to this article.

Table 1 has 159 entries rather than the 104 suggested by Enbridge. Most of the discrepancy is accounted for by the inclusion, in the table, of the 28 bodies of water encountered by “Line 9A”, that portion of the Enbridge pipeline (From Sarnia to Hamilton) that received NEB blessing in 2012 (Enbridge Inc. 2014a). Further, it seemed reasonable to list lakes, marshes, ponds and/or reservoirs which, while not strictly waterways (understood as “a channel for the escape or passage of water” (Oxford Dictionary 1923)), are nonetheless part of the water resource to be encountered by Lines 9A and 9, and exposed to risk in the event of a pipeline rupture. As well, tributaries of larger waterways (i.e. East Sixteen Mile Creek) were included. However, the only entries given a number (moving from west to east) were those meeting the criteria of being: a) an actual waterway; b) on the Line 9 route; and c) excluding smaller tributaries – resulting in a total of 119, roughly comparable to the 104 identified by Enbridge.

It is not surprising that Line 9’s route involves so many waterways. While ending in Quebec, much of the line runs through the province of Ontario, which according to the provincial government is home to “one-third of the world’s fresh water” (Ontario 2013). Therefore, it is also not surprising that considerable attention is given, in any project such as Line 9, to preventing contamination of this water resource.

What is surprising is that – given all this, Enbridge could have done so little.

Are these not worthy?

Enbridge claims that it “operates the world’s longest and most complex crude oil and liquids transportation system, with approximately 25,420 kilometres (15,795 miles) of crude pipeline across North America” (Enbridge Inc. 2014b). It also claims that it “makes it a priority to minimize its own environmental impacts” (Enbridge Inc. 2014c). Given this experience in pipeline construction and this expressed commitment to environmentalism, it is astonishing that Enbridge could find only six waterways out of 119 considered worthy of emergency shut-off valves.

Is it any wonder that the NEB was “not persuaded that Enbridge meets the requirements” (Young 2014, 1) considered as necessary to protect this water resource?

A little research allows us to refine the very long list of waterways listed in Table 1, and narrow it down to the major ones. A reasonable means by which to do this, is to rank these waterways by the size of their watershed or drainage area. Table 2 in the Appendix lists twelve of the largest crossed by Line 9A and Line 9.

One of those on this list, the Grand River, is in the path of Line 9A, and hence would not be part of the discussion between the NEB and Enbridge. That leaves, in the path of Line 9, eleven waterways with very large drainage areas. Given that Enbridge thought that only six waterways were worthy of emergency shut off valves within a kilometre of entering or leaving the waterway, then at least five on this list would have the Line 9 crude oil flowing under them without such protection. Which five did Enbridge judge unworthy?

Certainly as the tar sands crude ended its journey in Montreal, the Rivière des Prairies would qualify. Sometimes known in English as “Back River” (Beauregard 1968, 20), it is a channel from the Ottawa River which forms part of the network of rivers surrounding the Island of Montreal. Line 9 will enter the Rivière des Prairies just 10 kilometres from where it empties into the St. Lawrence River – a river with a drainage area of one million square kilometres. The mighty St. Lawrence carries a massive volume of water, discharging every second even more water than the Mackenzie River, longest river in Canada and second longest (after the Mississippi) in North America (Marsh 2006a). When Line 9 enters the Rivière des Prairies, it has to be seen as entering the St. Lawrence River. Presumably emergency shut off valves would be installed here.

Given that the Ottawa River with its drainage area of 146,300 square kilometres is also a massive and extremely important river in both Ontario and Quebec, no doubt emergency shut-off valves would be installed there.

That still leaves nine from the list on Table 2. Which would be excluded? Enbridge indicated that its criteria for identifying major water crossings included “highly populated areas (HPA), other populated areas, drinking water resources, environmentally sensitive areas and commercially navigable waterways” (Young 2014). Given that the Don River’s Drainage basin is home to 800,000 people (City of Toronto 2014), it would certainly qualify – but then so would the Humber, Credit and Rouge Rivers as well as Duffins Creek, all of them being in the Greater Toronto Area – the latter two also being near extremely environmentally sensitive Rouge River Valley.

That already takes our total to seven, and we haven’t yet included the historic Trent River with its network of canals; the Moira River, which cuts right through the middle of Belleville; the Sydenham River, just west of London, Ontario; or the Ganaraska River, near Port Hope. And then of course, there are the other 108 numbered waterways listed in Table 1, many of which go through environmentally sensitive areas, many of which are near very highly populated areas.

In fact, if you think about it, just which parts of Southwestern, Southern, and Eastern Ontario as well as Western Quebec – the land through which Lines 9A and Line 9 run – are not both highly populated and environmentally sensitive? These are, in fact, the most densely populated areas in all of Canada.

There are three bodies of water yet to be named – all of which could be negatively impacted by any spill in the pipeline. The rivers and streams listed in Table 1 each drain into one of Lakes Huron, Erie or Ontario. Together with Lakes Superior and Michigan, they comprise the Great Lakes, which, together with “their connecting channels form the largest fresh surface water system on earth. … Covering more than 94,000 square miles and draining more than twice as much land, these Freshwater Seas hold an estimated 6 quadrillion gallons of water, about one-fifth of the world’s fresh surface water supply” (Great Lakes Information Network 2014). This is not just a water resource for Ontario and Quebec – this is a resource for the entire planet.

Enbridge very prominently and very publicly notes on its web site that it is a very Canadian company, listed on the Toronto Stock Exchange since 1953, and, as of June 30, 2013, having 42 per cent of its shares held by Canadian institutional investors, 19 per cent by Canadian Retail investors (Enbridge Inc. 2014d). This very Canadian company should be aware of the very Canadian facts listed above.


Here’s a thought. Every one of the waterways and bodies of water encountered by Line 9 has an importance to people and an importance to the environment. Every one of the 119 waterways in the path of Line 9 deserves at the very least, an emergency shut-off valve where the pipeline enters the waterway, and another where the pipeline leaves the waterway, as a minimum protection against the hazards of a catastrophic oil spill. And perhaps we might agree that one kilometre is a bit too far away to be really effective.

These adjustments are not unreasonable. In fact, the NEB, in its letter to Enbridge, reminded them that the requirement to show adequate safety measures was “not restricted to MWCs, but also applies to all watercourses, water intakes, urban infrastructure, and ecologically sensitive areas” (Young 2014, 3).

These adjustments are ones that Enbridge can afford. In 2012, it was Canada’s seventh largest corporation by market capitalization, 12th by revenue (Report on Business Magazine 2013a; 2013b). In 2013, it reported net income of $1.365 billion, revenue of $32.918 billion and assets of $57.568 billion (Enbridge Inc. 2014e).

Here’s another thought. Surely there is a better way to manage our energy resources, than boiling mud in Alberta, diluting the product with toxic chemicals, and then forcing the resulting dilbit through 40-year old pipes near major population centres and the world’s largest supply of surface fresh water?

© 2014 Paul Kellogg

Appendix – Tables used in the article

Table 1 – Major Waterways and other Water Resources on or near Routes of Line 9A and Line 9 between Sarnia, Ontario and Montreal, Quebec

Name of Area (from West to East)
Waterway or body of water
Each area linked to appropriate map from “Line 9 Communities”
According to “The Atlas of Canada – Toporama”
Waddell Creek
Talfourd Creek
Bear Creek
Brown Creek
Hardy Creek
Adelaide Creek
Gold Creek
Sydenham River
Oxbow Creek
North Thames River
Stoney Creek
Fanshawe Lake
Wye Creek
Waubuno Creek
Caddy Creek
Reynolds Creek
Deer Creek
Washington Creek
Nith River
Little Turnbull Lake
Dean’s Lake
Pinehurst Lake
Spottiswood Lake
Fairchild Creek
Grand River
Barlow Creek
West Spencer Creek
Spencer Creek
1 Grindstone Creek
Lake Medad
Fisher’s Pond
2 Bronte Creek
3 Sixteen Mile Creek
East Sixteen Mile Creek
4 Credit River
5 Etobicoke Creek
Little Etobicoke Creek
6 Mimico Creek
7 Humber River
8 Black Creek
G. Ross Lord Park Reservoir
9 Westminster Creek
10 Don River
11 Wilket Creek
12 German Mills Creek
13 Rouge River
14 Highland Creek
15 Little Rouge Creek
16 Duffins Creek
West Duffins Creek
17 Petticoat Creek
18 Urfe Crek
19 Broughton Creek
20 Lynde Creek
21 Pringle Creek
22 Oshawa Creek
23 Farewell Creek
24 Harmony Creek
25 Tooley Creek
26 Darlington Creek
27 West Side Creek
28 Soper Creek
29 Bowmanville Creek
30 Wilmot Creek
31 Graham Creek
32 Port Granby Creek
33 Ganaraska River
34 Gage Creek
35 Cobourg Brook
36 Shelter Valley Creek
37 Cold Creek
38 Little Lake
39 Biddy Creek
40 Breakaway Creek
41 Proctors Creek
Matson Lake
42 Smithfield Creek
43 Trent River
44 Meyers Creek
45 Potter Creek
46 Moira River
47 Blessington Creek
48 Salmon River
49 Marysville Creek
50 Sucker Creek
Hempfly Marsh
51 Napanee River
52 Little Creek
53 Spring Creek
54 Wilton Creek
55 Millhaven Creek
56 Glenvale Creek
57 Collins Creek
58 Cataraqui River
59 Little Cataraqui Creek
Colonel By Lake
60 Butternut Creek
61 Steventown Creek
62 Abbey Dawn Creek
63 Moores Creek
64 Grass Creek
65 Mud Creek
66 Gander Creek
67 Brown’s Creek
68 Gananoque River
69 Stocking Hill Creek
70 Legges Creek
71 Gray’s Creek
72 Wiltse Creek
73 Larue Creek
74 Lyn Creek
75 Jones Creek
76 Golden Creek
Buells Creek Reservoir
Long Swamp
77 Butlers Creek
78 Lemons Creek
79 South Nation River
80 Wells Creek
81 Smades Creek
82 Bradleys Creek
83 Johnstown Creek
84 Drivers Creek
85 McLaughlins Creek
86 Sawmill Creek
87 Doran Creek
88 Parlow Creek
89 Flagg Creek
90 Strata’s Creek
91 Hoasic Creek
92 Aultsville Creek
93 Hoople Creek
94 Wereley Creek
95 Raisin River
South Raisin River
96 Stoney Creek
97 Finney Creek
98 Westleys Creek
99 Sutherland Creek
100 Rivière Beaudette
101 Gunn Creek
102 Wood Creek
103 Garry River
104 East Rigaud River
105 Rivière à la Raquette
106 Rivière Rouge
107 Ottawa River
108 Rivière Saint-Pierre
109 Rivière du Chêne
110 La Belle Rivière
111 La Petite Rivière
112 Rivière du Chicot
113 Rivière aux Chiens
114 Ruisseau Noir
115 Ruisseau La Corne
116 Rivière Mascouche
117 Ruisseau des Grandes Prairies
118 Rivière des Milles-iles
119 Rivière des Prairies (emptying into the St. Lawrence River)

(Created by the Author, derived from information in Ferguson 2014; Canada and Natural Resources Canada 2003)

Table 2 – Twelve major waterways (ranked by drainage area) on the Routes of Line 9A and Line 9 between Sarnia, Ontario and Montreal, Quebec

Name of Waterway
Drainage basin
Name of Area
Square kilometres
As used in “Line 9 Communities”
St. Lawrence River (into which Rivière des Prairies empties)
(Marsh 2006b)
Ottawa River
Ottawa/River Crossing
(Marsh 2006c)
Trent River
Quinte West
(Canada and Parks Canada Agency 2011)
Grand River
Cambridge – Plattsville
(Finkelstein 2006)
Moira River
(Sibul, Goff, and Choo-Ying 1974, 3)
Sydenham River
(Derived from data in St. Clair Region Conservation Authority 2008, 4)
Humber River
(Galway 2014)
Credit River
(Credit Valley Conservation 2009, 4)
Don River
(City of Toronto 2014)
Rouge River
(Sibul, Wang, and Vallery 1977, 1)
Duffins Creek
(Sibul, Wang, and Vallery 1977, 1)
Ganaraska River
Port Hope
(Ganaraska Region Conservation Authority 2009)
(Created by the author from information available in the Sources listed)


Beauregard, Ludger. 1968. Toponymie de La Région Métropolitaine de Montréal. Québec: Ministère des Terres et for̂ets, Commission de Géographie.

Canada, Government of, and Natural Resources Canada. 2003. “The Atlas of Canada – Toporama.” Accessed October 12, 2014.

Canada, Government of, and Parks Canada Agency. 2011. “Geographic Context.” Trent-Severn Waterway National Historic Site of Canada. Accessed October 12, 2014.

City of Toronto. 2014. “Don River Watershed – Fishing – Swimming – Canoeing.” Toronto. Accessed October 12, 2014.

Credit Valley Conservation. 2009. “Credit Valley Conservation: Rising to the Challenge.” Mississauga: Credit Valley Conservation.

Enbridge Inc. 2014a. “Line 9A Reversal (Phase I) Overview.” Enbridge. Accessed October 14, 2014.

———. 2014b. “Our Pipelines.” Enbridge. Accessed October 12, 2014.

———. 2014c. “Minimizing Environmental Impacts.” Enbridge. Accessed October 12, 2014.

———. 2014d. “Ownership.” Enbridge. Accessed October 14, 2014.

———. 2014e. “Financial Information.” Enbridge. Accessed October 12, 2014.

Fawcett, Max. 2014. “National Energy Board to Enbridge: You Need to Do Better.” Alberta Oil: The Business of Energy. Accessed October 12, 2014.

Ferguson, Emily. 2014. “Local Maps.” Line 9 Communities. Accessed October 12, 2014.

Finkelstein, Maxwell W. 2006. “Grand River.” The Canadian Encyclopedia, February 7, Online edition. Accessed October 12, 2014.

Galway, Robert. 2014. “History and Origins of the Humber River Toronto, Ontario.” Origins of the Humber River Watershed and The Ice Ages Toronto, Ontario. Accessed October 12, 2014.

Ganaraska Region Conservation Authority. 2009. “Ganaraska River Background Report: Abiotic, Biotic and Cultural Features.” Port Hope: Ganaraska Region Conservation Authority.

Great Lakes Information Network. 2014. “The Great Lakes.” The Great Lakes Information Network. Accessed October 12, 2014.

Marsh, James. 2006a. “Mackenzie River.” The Canadian Encyclopedia, February 7, Online edition. Accessed October 12, 2014.

———. 2006b. “St Lawrence River.” The Canadian Encyclopedia, February 7, Online edition. Accessed October 12, 2014.

———. 2006c. “Ottawa River.” The Canadian Encyclopedia, December 20, Online edition. Accessed October 12, 2014.

McCarthy, Shawn. 2014. “NEB Delays Enbridge Plan to Ship Oil through Reversed Line 9 Pipeline.” The Globe and Mail, October 9. Accessed October 12, 2014.

McGowan, Elizabeth, Lisa Song, and David Hasemyer. 2012. The Dilbit Disaster: Inside the Biggest Oil Spill You’ve Never Heard Of. Kindle. InsideClimate News.

Ontario, Government of. 2013. “About Ontario.” Information. Ontario.ca. Accessed October 12, 2014.

Oxford Dictionary. 1923. “Water-Way, N.” OED Online. Oxford University Press. Accessed October 14, 2014.

Paris, Max. 2013. “Enbridge’s Kalamazoo Cleanup Dredges up 3-Year-Old Oil Spill.” CBCnews, September 6, sec. Politics. Accessed October 12, 2014.

Report on Business Magazine. 2013a. “Canada’s 100 Biggest Companies by Market Cap.” The Globe and Mail. Accessed October 14, 2014.

———. 2013b. “Canada’s 100 Biggest Companies by Revenue.” The Globe and Mail. Accessed October 14, 2014.

Sibul, U., K. Goff, and V. Choo-Ying. 1974. Water Resources of the Moira River Drainage Basin. Water Resources Report 6. Toronto: Ontario Ministry of the Environment. Accessed October 12, 2014.

Sibul, U., K.T. Wang, and D. Vallery. 1977. Ground-Water Resources of the Duffins Creek-Rouge River Drainage Basins. Water Resources Report 8. Toronto: Ontario Ministry of the Environment. Accessed October 12, 2014.

St. Clair Region Conservation Authority. 2008. “Thames-Sydenham and Region Watershed Characterization Summary Report.” Strathroy: Upper Thames River Conservation Authority.

Young, Sheri. 2014. “National Energy Board – Letter to Enbridge Pipelines Inc. Condition 16 Filing – Line 9 Intelligent Valve Placement Methodology and Results (A63315),” October 6. Accessed October 12, 2014.

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