CO2 pipelines operate at very high pressure (much higher than a natural gas pipeline). CO2 is also an asphyxiant that is colorless, odorless, and heavier than air. Those exposed to high concentrations of CO2 may experience fainting, incapacitation, asphyxiation, respiratory and cognitive damage, cryogenic burns, and even death.

• Pipeline ruptures: If a rupture occurs, the result could be a rapid, uncontrolled release of CO2 over a large swath of land. There is little to no independent expert modeling examining the consequences and area of impact of a CO2 pipeline rupture. What will happen in the case of a pipeline leak – above ground, underground, or underwater? How far will the CO2 disperse, and what will its effects be?
• First responders and health professionals: CO2 pipelines pose unique problems for first responders and health care providers. Because CO2 is colorless and odorless, both victims and first responders have no way of knowing what is causing the health problems. In addition, first responders require special equipment, including non-internal combustion engines, to respond to a CO2 disaster. What kind of burden will this put on local EMS and health providers in the case of a pipeline rupture or accident? How will they be prepared to respond, given their unique needs?
• Air pollution: Industrial sources like ethanol plants with carbon capture can still emit toxic, health-damaging air pollution (e.g., volatile organic compounds, particulate matter, etc.). The air pollutants emitted by these facilities can affect lung and heart function, imply a higher risk of respiratory disease and cancer, and increase smog, which can affect air visibility, damage plant life, and be deadly to humans.
• Regulatory gaps: Federal regulations governing this new and risky technology are limited and under review. For example, the federal rules don’t currently require CO2 pipelines, which can rupture, to be a safe distance from sensitive sites. How can the PUC ensure the safe routing of this pipeline in the absence of credible guidance on critical issues like this?

One of the things that Minnesota takes immense pride in is our natural heritage. Beyond the damage done during the construction phase of the project, what happens to the land, water, air, and all living creatures that depend on a vibrant ecosystem for survival?

• Dangers to water and waterbodies: The proposed route for Summit’s pipeline network includes many water crossings, wetlands, aquifers, and other sensitive water bodies. More research and analysis are needed to understand how CO2 disperses in water and what risks a CO2 pipeline leak or rupture poses to Minnesota’s precious waters and the fish, amphibians, reptiles, waterfowl, birds, and insects that rely on it to survive.
• Water use: Carbon Capture and Sequestration (CCS) can also double water requirements and increase toxic wastewater discharge. There must be a careful and case-specific assessment of how the installation and operation of carbon capture equipment will impact and exacerbate existing water use and pollution sources.
• Land degradation: This project is going to cut through roads, ditches, tile lines, and prime farmland—are we supposed to take it on faith that this will be “back to normal” in two or three years? Other pipeline projects in the Midwest are still suffering yield reduction and damage to land years after project completion and “restoration”.
• Geohazards: The geotechnical assessment in the Environmental Assessment Worksheet (EAW) is cursory and inadequate. A CO2 pipeline in Satartia, MS, experienced a dangerous rupture because the ground it was in collapsed after some heavy rain. This could and should have been anticipated by the company if they had properly studied the region for geohazards and other geological risks. Minnesota shouldn’t make the same mistake.
• Drilling slurry and frac-outs: Summit’s application includes the use of a bentonite drilling slurry for drilling underneath water crossings. Bentonite drilling slurry is a potential hazardous waste and, when released into surface water, expands and can coat the gills of fish, resulting in large fish kills. Summit’s claim that this poses no risk falls flat given Minnesota’s very recent track record of frac-outs on the Line 3 project. What assurances do we have that this method of drilling won’t have the same disastrous effects?

In addition to the direct impacts of the 28 miles of pipeline included in Summit’s application, the EIS must consider all indirect and cumulative impacts of Summit’s entire project in Minnesota. Allowing Summit to artificially segment permitting requests for multiple concurrent projects on one pipeline could prevent a thorough review of the cumulative impacts and potential environmental and climate damages of an unnecessary Carbon Capture Utilization and Sequestration (CCUS) project and CO2 pipeline.

Summit and its supporters are making big promises about the benefits to Minnesota’s rural communities—in employment, tax income, and economic growth—but provide very little credible evidence to back up these promises. Independent academics from the University of Iowa have pointed out that these claims overestimate the benefits and ignore the costs to rural communities, local governments, and the surrounding environment.

• How many and what kind of jobs will this project really bring to local communities?
• What are the hidden costs—like the burdens on local government or community resources?
• Summit makes vague claims that local farmers will see huge revenue gains by getting access to low-carbon fuel markets. Can those claims be backed up with real numbers?
• How will this project really impact the local tax base?
• Who will be liable if there’s an accident with the pipeline or construction causes damage to the natural environment, farmland, or built structures?

Summit spends many pages in its application justifying its conclusion that there are no environmental justice concerns raised by this project. But Fergus Falls—the site of the carbon capture facility and the start of the pipeline—is a defined environmental justice community. The White House Environmental Justice Advisory Council has identified carbon capture as among the “types of projects that will not benefit a community.” The environmental justice implications of this project must be assessed by actual environmental justice advocates and experts, not the company with an interest in building it.

Summit says its pipeline network is needed to reduce Minnesota’s carbon emissions and contribution to climate change. But after decades of development and repeated attempts to get carbon capture off the ground, the technology has never been successful at scale.

• Energy Intensive: Will this project really reduce the emissions from ethanol facilities? Carbon capture is a very energy-intensive technology, and most of the energy comes from fossil fuels (or diverts renewable energy away from the things we really need it for). An Archer Daniel Midlands facility in Illinois has used carbon capture on ethanol production for a number of years. But the emissions from that facility went up, not down. How is that a climate solution?
• Enhanced Oil Recovery: Summit claims it has no plans to use the captured CO2 in a process known as Enhanced Oil Recovery (EOR), but there is nothing to stop them from changing their plans. Meanwhile, most CO2 captured in the US today is used for EOR, and this pipeline goes to North Dakota where EOR takes place. An EIS must consider the high likelihood that CO2 captured in MN will be used to extract and burn more fossil fuels and the greenhouse gas implications of that.
• Extending reliance on coal (part 1): Minnkota is partnering with Summit on their CCUS project (Project Tundra) at the Milton R. Young Station, a 700+ MW coal-fired power plant near Center, ND. Summit’s CO2 pipeline project will be helping a coal-burning power plant continue to run. When considering the environmental impacts of the CO2 pipeline in Minnesota, the pollution and emissions from this coal plant also need to be considered.
• Extending reliance on coal (part 2): Otter Tail Power, which supplies power to the Green Plains ethanol facility in Fergus Falls, recently announced it would be keeping its Coyote Station coal plant open because of increased needs from large power customers. Carbon capture is very energy intensive – if the use of it is leading to the ongoing operation of one of the dirtiest coal plants in the country, that should be included in this project’s GHG assessment.