Transition Initiative Kenora
Transition Initiative Kenora (TIK) is a community-led response to climate change and shrinking supplies of cheap energy. We're building a more resilient community and improving the quality of life for everyone in Kenora and the Treaty 3 area.


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Climate Impacts Assessment for Line 3 and Kinder Morgan

Earlier this spring, Transition Initiative Kenora participated in the public review of Environment and Climate Change Canada’s estimate of upstream greenhouse gas emissions from Enbridge's Line 3 replacement and Kinder Morgan's Trans Mountain Expansion projects.  These reports were commissioned by Cabinet as part of the Interim Measures for Pipeline Review, a patchwork of interim policies aimed at enhancing a flawed and deficient federal regulatory review process that has been in place since 2012.  The final reports on these assessments were released this month.

Upstream emissions include sources of carbon pollution that occur in order to fill the pipeline, such as emissions related to oil extraction and upgrading or other pre-transportation processing.  Other emissions happen during operation and downstream when the end user burns the oil.

Read the Line 3 Upstream Emissions Analysis here.

Read the Kinder Morgan Upstream Emissions Analysis here.


In comments we submitted to the agency, TIK raised questions about how these assessments might be treated given that they have no basis in law.  We also pointed out that the assessments fail to consider the projects in the context of any climate policies developed since September 2015, including the Paris Agreement, the Alberta Climate Leadership Plan, or any other Canadian federal or provincial policies that seek to limit greenhouse gas emissions.  We critiqued omissions and methodological assumptions about the equivalency of rail and pipelines as fully interchangeable methods of transporting crude oil.  

Read TIK's comments on the Line 3 Upstream Emissions here

Read TIK's comments on the Kinder Morgan Upstream Emissions here


In the final draft of each of these reports, released in mid-November, none of our comments or questions was addressed.  In fact, the only significant revision made in either assessment was to the emissions intensity estimates for conventional heavy crude oil, with a result that the net anticipated emissions from each project rose several megatonnes annually over the draft estimates. 

ECCC estimates that Line 3 will introduce 21 to 27 MT of new upstream emissions annually, while Kinder Morgan will add another 21 to 26 MT.   This is equivalent to adding 4.4 to 5.7 million new cars to the roads or bringing 6-8 new coal plants online each year.

Use the U.S. Environmental Protection Agency's handy emissions equivalency calculator to see how big a carbon footprint these projects have.     


Canada currently produces just over 730 MT of greenhouse gases per year, and our current climate policy that is part of our international commitment through the United Nations Paris Agreement is to reduce those emissions to 524 MT by 2030. Obviously adding new emissions undermines our potential for success at reducing our pollution levels.  Permitting new carbon pollution for projects that have decades-long lifespans is completely irresponsible in the climate change era.

Canada is trying to position itself as a global climate leader.  If we're sincere, we need to acknowledge that permitting new carbon pollution for projects that have decades-long lifespans is completely irresponsible in the climate change era.

Richard Tolton