Topics of Importance Environment & Land Management

2015 Performance


Although we do not use water to transport liquid hydrocarbons or natural gas, we periodically require large volumes of water to hydrostatically test the integrity of our new or existing pipelines and storage tanks.

In 2015, our Chief Sustainability Officer met with 30 individuals and organizations in Canada and the U.S. who are active on water issues to better understand their perspectives on the water risks associated with our projects and operations, and to identify opportunities for joint projects or partnerships that could help advance new approaches to water protection in areas in which we operate.

Before we construct a pipeline, we survey its entire route to identify wetlands, water bodies and sensitive plant and wildlife. We use the survey information to develop Environmental Protection Plans that help us mitigate our environmental impact.

Biodiversity Conservation and Land Management

It is important for us and for others that we protect and conserve environmentally sensitive areas and areas of high biodiversity, and we recognize that we must prioritize these activities in our project planning, construction and operations.

Project Planning, Construction and Operation

Canadian and U.S. regulations require us to submit detailed environmental and socio-economic impact assessments before we construct energy-related projects. These plans inform our consultations with regulators, landowners, and Aboriginal and Native American and right-of-way communities throughout the life cycle of our projects.

We also consider options to avoid and mitigate environmental impacts in our project planning phase, and incorporate these options into project-specific Environmental Protection Plans (EPPs).

Actions we take to eliminate or minimize the short- and long-term impacts of construction and operations of our pipeline infrastructure can include:

  • minimizing the pipeline length to the extent practicable so as to minimize its environmental impacts, and whenever possible, installing pipelines within existing rights-of-way,
  • analyzing various routing alternatives to determine whether they would avoid, minimize or mitigate our impacts to natural resources, including environmentally sensitive areas,
  • narrowing the right-of-way to minimize the impact on sensitive plant species and avoid or minimize conflicts with existing or proposed residential and agricultural lands,
  • avoiding construction activities during certain times of the year ( avoid fish spawning season),
  • avoiding disturbance to sensitive wetland areas, and
  • designing water crossings to minimize impacts to rivers and streams.

We evaluate wetlands and watercourse crossings on a case-by-case basis to minimize construction impacts, but when we must cross them, we use a variety of measures to minimize and mitigate our impacts and endeavor to restore impacted areas to as close to their original conditions as possible.

We also incorporate environmentally sound construction procedures into all of our projects, and provide related training and guidelines to employees and contractors.

Once a project is under construction, regulators may conduct inspections and audits to verify our compliance with proposed mitigation strategies and to provide feedback on our activities. We address any findings from regulators through corrective action plans that our project teams implement. As needed, we also re-evaluate risks to habitat to ensure that our EPPs are still appropriate, or need to be modified to reflect changing conditions.

In joint-venture projects where environmental responsibilities fall under our scope, we share any environmental management strategies with our partners.

After a project has been constructed, we may be required to submit an As-Built Report and Post-Construction Monitoring Report to regulators. Once we have submitted these reports, the regulator makes these documents available to the public through its website.

Beyond the regulatory framework for environmental assessment and monitoring, we also support biodiversity conservation projects with local communities and conservation organizations. For more information, please see the Community Investment section of this report.

Although there are currently no standard biodiversity metrics at an industry or regulatory level in Canada or the U.S, there is an established trend at both the regulatory or voluntary level toward using biodiversity or conservation offsets. To that end, we are active in a number of communities of practice at the local, regional and global levels that are engaged in developing appropriate methodologies and tools. These include the Alberta Association for Conservation Offsets, The Natural Step Canada, and the International Institute for Sustainable Development.

Protecting Sensitive Habitats and Species at Risk

All of our business segments comply with federal, provincial and state requirements. In Canada, these requirements include the federal Species at Risk Act (SARA), which aims to protect flora and fauna and conserve biological diversity.

Liquids Pipelines – Using digital mapping technology, LP has mapped its Canadian system to identify areas along its rights-of-way where there may be species-at-risk habitat. LP now regularly updates its maps to ensure that it is working with the most accurate and effective data.

Before we construct a pipeline, we survey its entire route to identify wetlands, water bodies and sensitive plant and wildlife. We use the survey results to develop Environmental Protection Plans that help us determine areas that will require alternative construction techniques, timing restrictions (i.e., to minimize impacts during breeding or spawning seasons for certain sensitive species), or route variations (to minimize or avoid impacts to sensitive plant species). The plans, which include site-specific procedures around maintenance and operational activities, also help us minimize our impacts on sensitive species when we must traverse their habitat. For example, we have put such plans in place to protect boreal caribou populations in the Northwest Territories and Alberta, the Karner blue butterfly in Wisconsin, and Redside Dace (an endangered species of ray-finned fish) in Ontario.

Regulators also apply stringent conditions to our mitigation efforts when we must traverse certain sensitive habitats or protected areas. For example, in the U.S., regulators have mandated how we maintain our rights-of-way for pipelines that traverse National Forests.

Some of our pipelines are located in lakes, beneath navigable waterways or within areas of high biodiversity. For those areas, we may develop site-specific inspection or maintenance procedures to ensure that we comply with all regulations.

Gas Distribution – GD historically has not had a significant impact on environmentally sensitive areas or areas of high biodiversity. The majority of GD’s pipelines are installed in urban environments within existing road rights-of-way in previously disturbed soil. By their nature, these areas are not typically areas of high biodiversity.

However, occasionally, a specific localized area may be identified as being environmentally sensitive, due to a wetland or watercourse, or a species at risk, in which case GD implements environmental screening or environmental assessments (depending on the project scope) to identify any features or species that may be impacted by construction or maintenance activities.

If identified, GD then consults with applicable regulatory agencies and implements all required mitigation measures prior to and during construction or maintenance activities. Mitigation can include such measures as using directional drilling instead of open cutting, and sediment and erosion control. GD restores any areas it has temporarily disturbed through pipeline construction and maintenance in accordance with regulatory requirements.

With regard to protected areas, GD has an easement on the western edge of Springwater Provincial Park near Midhurst, Ontario. GD's franchise area in Ontario also includes the Niagara Escarpment and the Oak Ridges Moraine, but utility facilities are permitted within these protected areas. Species at risk that GD has identified in past projects include Redside Dace, Butternut trees, Eastern Meadowlark, Bobolink and Blanding’s Turtle.

Green Power, Transmission and Emerging Technology  – GPT&ET takes multiple measures to protect and minimize impacts on species at risk during both construction and operation at its facilities. Some of these measures include restricting activity during key times, curtailing operations, establishing set-back distances from sensitive habitats, erecting physical barriers, and implementing wildlife deterrent strategies and habitat restoration. As a result of these measures, GPT&ET has witnessed a reduction and prevention of negative impacts, including on bird and bat mortalities. The exact number of species at risk in its operating areas across Canada and the U.S. is not well known, by and large due to a lack of scientific consensus and baseline population numbers. However, species at risk that we have encountered at GPT&ET sites include little brown myotis and northern myotis (bat species), eastern small-footed bats, golden eagles, bald eagles, ferruginous hawks, burrowing owls, bobolinks, barn swallows, bank swallows and desert tortoises.

The results of wildlife monitoring in areas where our wind turbines and transmission lines operate indicate that some bird and bat mortalities occur annually, which has an impact on biodiversity in these areas. In response, we have reduced impacts by putting mitigation and deterrents in place. For example:

  • At our Talbot, Underwood, Cruickshank and Greenwich wind farms in Ontario, we curtail the operation of select wind turbines during peak activity season for bats. At night, when bats are most likely to be impacted by turbine blades, we stop the selected wind turbines at wind speeds of 5.5 meters per second (m/s) or less. Over time, we have seen a significant reduction in overall bat mortalities at these sites due to this action.
  • In 2014, we installed bird diverters on our Montana-Alberta Tie Line to make the power transmission line more visible to birds so as to avoid collisions. We have seen the number of waterfowl collisions decrease since we installed diverters. Additionally, we impose restrictions on activities and access during sensitive times for wildlife, such as nesting and lekking periods, to reduce stress and potential impacts.
  • In Colorado, we have put in place a bird and bat conservation strategy to minimize the potential impacts to raptor populations, including a local nesting pair of golden eagles.

For more information on GPT&ET efforts to mitigate wildlife impacts, please see Impact Mitigation in this section of the report.

Vegetation Management and Restoration

When managing vegetation at our facilities and on our pipeline rights-of-way, we use the most appropriate methods of keeping them clear for inspection. In conducting this work, we take into account the visible results and perceived impacts on landowners and communities. Our weed control and re-vegetation activities are designed to stop the encroachment of invasive species, mitigate erosion issues and enhance biodiversity.

Some of our recent initiatives related to vegetation management and restoration include the following:

  • In 2015, LP updated its Vegetation Management Minimum Guide, which outlines the minimum requirements it must meet to ensure environmental compliance, as well as best practices in weed and vegetation control techniques.
  • Post-construction activities at our Blackspring Ridge wind farm in Alberta included seeding of native prairie. Since 2014 (one year post-construction), we had re-established a quarter of the proposed native prairie areas across the entire wind farm.
  • From 2015 to 2020, we will invest $100,000 in Return the Landscape, a native plant rescue and restoration organization, such that it can restore habitat on a 200-acre parcel of land on the site of our 1,100-acre Sarnia Solar facility in Sarnia, Ontario.  For more information, please see the Stakeholder Engagement section of this report.

Protecting Soils and Waterways

Our core business is to safely and reliably transport oil and gas through a network of pipelines, and we are working constantly to improve the methods we use to prevent and detect leaks and releases.

An important focus area for us is protecting the environmental integrity of soils and waterways in and around our projects and operations.

Project Construction and Operation – We carefully select our pipeline routes and line locations and maintain world-class standards for engineering and design, including special considerations for areas such as road, rail, river and creek crossings. We take the same rigorous approach with facilities such as stations, terminals and plants.

In many cases, we use horizontal directional drilling when crossing beneath watercourses and, before doing so, always obtain permits from the required authorities and government agencies. We further maintain pipeline integrity through regular inspections of bridge and watercourse crossings.

Our liquids pipelines system crosses numerous rivers and widely varying terrain. To protect the integrity of this vast continental system, we closely monitor geohazards (environmental forces such as floods, soil erosion, seismic activity and slope movement). For more information, please see Maintaining the Fitness of Our Systems and Leak Detection section of this report.

We provide project planning staff with environmental awareness training on how to identify watercourses and wetlands to ensure that we identify and protect them during the planning process. We also train field employees on the importance of protecting watercourses during our pipeline construction and maintenance activities. This training includes proper sediment erosion control methodology, along with effective spill response and notification.

In areas where we have conducted pipeline integrity digs, we have a post-reclamation monitoring program to ensure that we restore all of these sites to their pre-excavation condition, as determined by third-party environmental inspectors.

Assessing Water Risks – LP regularly assesses the risk to waterways should we experience a crude oil leak. Its assessments include identifying impacted waterways, determining the distance the crude oil could migrate downstream and mapping municipal water supply intakes. Based on the results of these assessments, we work with municipalities to develop contingency plans. We also install additional valves to limit the volume of crude oil that could be released in the event of an incident.

We assess operational water risks—such as fisheries habitats, aquatic species at risk, wetlands habitat, and surface and ground water impacts—on a project-by-project basis through the environmental assessment or screening processes that we must undergo before we can construct or maintain existing pipelines or related infrastructure. These risk assessments are typically part of the regulatory process we are required to undergo in advance of obtaining a “Leave to Construct,” and are usually conducted by third-party environmental consultants.

Sometimes we are also required to conduct hydrogeological and hydrologic risk assessments as part of pre-construction permitting and approval process. These assessments give us information on shallow geological conditions, groundwater chemistry and the potential for other impacts along with proposed mitigation measures.

Before GD can install natural gas distribution services on private property, we must consult with the landowner/customer to ensure that we thoroughly identify and mitigate any risks to the local water quality and quantity prior to construction.

Through bill inserts and its public website, GD also provides its customers with information on the safety risks associated with flooded or snow-covered above-ground pipeline distribution infrastructure such as meter sets.

Being Prepared for Emergencies – We have comprehensive crisis management and emergency response plans in place to help us respond rapidly anywhere, should a spill or emergency occur, including on water. We also continually train our employees and contractors, and provide training to first responders in our areas of operation throughout Canada and the U.S. to help prepare them for a spill or emergency in the event that one should occur. The training involves staging drills, emergency exercises and equipment deployments each year so that we can test and refine our response plans and have the shared knowledge and experience to respond to any incident. For more information, please see the Emergency Preparedness & Response section of this website.

Working with Regulators, Conservation Authorities and Local Water Utilities – We engage with regulators on water management issues through a number of industry associations, including the Canadian Energy Pipeline Association (CEPA), the Canadian Gas Association (CGA) and the Alberta Association for Conservation Offsets (AACO), which deals with wetlands. We also maintain direct contact with regulators at various jurisdictional levels to facilitate discussions on specific projects or concerns. We take a proactive approach with regulators by communicating directly with them on project specifics to identify regulatory requirements.

We routinely contact river basin management authorities or conservation authorities (CAs) to identify local water management concerns and regulatory requirements. For example, given that our GD business segment primarily serves urban centers, we communicate regularly with local CAs, such as the Toronto and Region Conservation Authority and the Credit Valley Conservation Authority about our construction and maintenance activities.

We contact local water utilities during the project planning process to identify buried infrastructure and to coordinate long-term infrastructure expansion plans to avoid future conflicts. We also contact them to identify the location of municipal water intakes as part of our risk assessment and mitigation process, and to develop and implement emergency response plans.

Engaging with Special Interest Groups – We consult with special interest groups on a project-by-project basis as part of the stakeholder consultation process related to a project.

These groups may also include industry associations such as CEPA, which works to define and implement best practices that improve industry performance in environmental management, including watershed protection. For example, to better understand the behavior and environmental impacts of a broad range of crude oil types in water, CEPA, on behalf of industry and alongside other industry associations, co-sponsored a North American-focused, independent, science-based study conducted by an expert panel of the Royal Society of Canada. The results of the study, which were released in the fall of 2015, will assist industry with future environmental risk assessments and help inform and improve our industry’s spill preparedness and response capabilities.

Stakeholder Engagement – We engage with stakeholders at a local level to provide awareness around our programs to maintain the fitness and reliability of our systems, and to address concerns about the potential impacts of spills to water quality or quantity. For more information, please see the Stakeholder Engagement section of this report.

GD undertakes water-well monitoring programs for construction projects that are in proximity to residential wells. It collects water samples before and after construction, and analyzes them to verify water quality. It then promptly deals with any discrepancies between the water quality data resulting from construction.

We also communicate the importance of watershed management and protection to local communities along our pipeline rights-of-way through the support of local environmental initiatives and projects to restore and enhance habitat along streams, rivers and wetlands. Community investment at the local level demonstrates our commitment to sound environmental stewardship. For more information, please see the Stakeholder Engagement section of this report.

Neutral Footprint Commitments

Through our Neutral Footprint commitments, we pledged to reduce the environmental impact of our liquids pipelines expansion projects within five years of their occurrence by:

  • planting a tree for every tree we removed,
  • conserving an acre/hectare of natural habitat for every acre we permanently altered, and
  • generating a kilowatt hour of renewable energy for every additional kilowatt hour of conventional electricity that our Liquids Pipelines business segment (LP) used in its operations above 2008 levels.

We have met these commitments since we first made them in 2009. After consulting with internal and external stakeholders regarding the future of the commitments, in 2015, we began developing a new generation of environmental commitments that better reflect our changing business needs and the expectations of our local stakeholders.

In 2016 we will update our commitments to reducing our environmental footprint to reflect an increased focus on improving our performance regarding GHG reduction, water protection, waste reduction, land and species conservation, and new projects and partnerships that respond to local environmental priorities.

Water Use and Management

Across all of our operations, we strive to meet or exceed all regulatory requirements, including those pertaining to water use and management.

Engaging on Water Management and Protection Issues

In 2015, our Chief Sustainability Officer (CSO) met with 30 individuals and organizations in Canada and the U.S. who are active on water issues, including environmental groups, Aboriginal and Native American individuals and groups, state agencies, regulators, industry associations, local watershed group and international research groups.

Her purpose was to ensure that we understand their perspectives on the water risks associated with our projects and operations. She also sought to explore opportunities for joint initiatives that could help advance new approaches to water protection in areas in which we operate.

In 2016 we are exploring opportunities in Saskatchewan and Minnesota for innovation projects on water protection. For more information, please see the Significant Sustainability Challenges & How We Are Responding section of this report.

Water Withdrawal and Disposal

Across all of our operations, we strive to meet or exceed all regulatory requirements, including those pertaining to water withdrawal and disposal. We are currently assessing ways to enhance our collection of data on water usage with a view to developing a standardized process for tracking our performance in this area.

Hydrostatic Testing – Although we do not use water to transport liquid hydrocarbons or natural gas, we periodically require large volumes of water to hydrostatically test the integrity of our new or existing pipelines and storage tanks.

Hydrostatic testing of pipelines involves filling a segment of a pipeline with potable water from an approved municipal water source—generally withdrawn locally from the environment or from municipal sources, or delivered on-site by a third-party water supplier—and carefully raising the operating pressure on the segment for a prescribed period while continuously monitoring it to confirm its integrity. When we conduct these tests, we follow company policy and regulatory standards.

The total volume of water that we ultimately consume through hydrostatic testing is relatively small because we return almost all of it to the environment.

We analyze and treat the test water that we return to the environment, as all of it must meet the discharge criteria that relevant regulatory agencies establish. Typically we only need to filter the particulate matter from the water that we have used to hydrostatically test new pipelines.

We also engage specialized waste disposers to remove any water that is not found to be suitable for discharge to the environment, and to dispose of it in accordance with applicable regulations.

In some instances, regulators require water quality information before we can discharge it or before a waste disposal facility will accept it. For example, provincial and federal regulations require that MP in Canada tests all of the water it uses before it discharges it.

Our operations and engineering departments measure and track the water we use for hydrostatic testing for the majority of our larger projects at more than 50 percent of our operational locations. They track water by the following categories: total volumes withdrawn and discharged; destination of discharged water; and volume by treatment method.

In 2015:

  • MP in Canada used approximately 239 megaliters of water to hydrostatically test new pipelines. It used approximately 389 megaliters in 2014 and 195 megaliters in 2013. Fewer new projects reached completion in 2015 than in 2014, hence the year-over-year decrease.
  • MP in Canada returned approximately 239 megaliters of the water it used for hydrostatic testing to the environment, and did not dispose of any water through waste disposers. In 2014, it returned approximately 387.5 megaliters of the water it used, and disposed of and 1.5 megaliters. In 2013, it returned approximately 192 megaliters, and disposed of three megaliters.  Before returning water to the environment, MP verifies that it is free of contaminants. MP conducts this work in a manner that complies with all appropriate regulatory jurisdictions.
  • MP in the U.S. used approximately 321 megaliters of water to hydrostatically test new pipelines.  It used approximately 711 megaliters in 2014 and 747 megaliters in 2013. MP in the U.S. returns all of the water it uses to the environment, either directly or through waste disposers.
  • LP Canada used approximately 96 megaliters of water from municipal, industrial or natural sources for hydrostatic testing, compared with an estimated 17 megaliters in 2014 and an estimated 1.5 megaliters in 2013.
  • LP in Canada returned approximately 96 megaliters to the environment or to the original industrial source, compared with approximately 16.8 megaliters—or 97 percent—in 2014.
  • LP U.S. used approximately 102 megaliters of water from municipal and natural sources for hydrostatic testing in 2015. In 2014, LP U.S. did not conduct any hydrostatic testing. In 2013, LP U.S. used approximately 110.9 megaliters of water from municipal or natural sources for hydrostatic testing.
  • In 2015, LP U.S. returned approximately 103 megaliters to the environment, after having met all necessary water quality criteria. (The discrepancy between the water that LP U.S. withdrew in 2015 and the water it returned is due to the fact that it used different measuring and metering methodologies for the two years.) In 2013, it returned approximately 110.5 megaliters to the environment. It disposed of the remainder through waste disposers.
  • GD used approximately 0.3 megaliters of municipally treated water to hydrostatically test new pipelines in 2015, compared with 5.6 megaliters in 2014 and 5.9 megaliters in 2013.
  • GPP&ES used approximately 4.4 megaliters of water from municipal or natural sources for hydrostatic testing in 2015, compared with approximately 2.5 megaliters in 2014.


Liquids Pipelines - In 2015, LP continued its system-wide groundwater monitoring program, under which it regularly monitors its facilities to identify potential impacts to groundwater and to maintain compliance with regulatory requirements where they exist. LP conducted site investigations at several stations in 2015 where it had previously noted groundwater impacts.

LP also continued its efforts to manage groundwater contamination associated with our Hardisty Caverns. Prior to our acquisition of the facility, the clay liner used to contain the brine in cavern operations had leaked. However, LP now operates a groundwater recovery well system to extract the contaminated groundwater either for reuse in the brine pond as makeup water, or for disposal in an on-site disposal well. The recovery wells serve two purposes. They slowly clean the groundwater by removing the contaminated water. And they hydraulically contain the site, stopping further migration of the brine contamination. In 2015, LP connected five additional recovery wells to the system and upgraded the system to handle greater water volumes. It also conducted further environmental site assessments in 2015 to assist the ongoing remediation work.

In 2015, LP conducted pilot-scale testing of a surfactant injection and multi-phase extraction groundwater remedial system at its Bronte Junction site near Oakville, Ontario. The system is designed to treat groundwater contamination identified in shallow, fractured bedrock. Subject to stakeholder consultation, LP will initiate full-scale operations in 2016.

As part of its contaminated site management program, LP continued to operate an air-sparging system at the site of a February 2007 third-party pipeline strike near Exeland, Wisconsin. LP also installed a bioventing (air-sparging in the unsaturated zone) system in late 2014 at South Cass Lake, Minnesota pumping station and 2015 was the first full year of operation. Both of these systems are treating residual hydrocarbons and directly reducing groundwater impacts.

Throughout 2015, LP continued operating belt skimmers at our North Cass Lake, Minnesota, pumping station to recover free product that LP had discovered in 2010 and that was the result of a leaking flange. As a result of its recovery efforts, LP has maintained a stable groundwater contamination plume, and has protected two nearby residential potable wells and the on-site well.

For LP Canada and LP U.S., storm water makes up the majority of the facility water releases. LP discharges this water into the environment in a controlled manner and does not significantly impact any water bodies.

Gas Distribution; Gas Pipelines, Processing & Energy Services; and Green Power, Transmission & Emerging Technology – GD, GPP&ES and GPT&ET do not significantly affect any water bodies or related habitats by discharging water or runoff. In addition, GD and GPP&ES only use closed loop water-related processes that result in minimal water loss.

Rainwater Harvesting

GD has incorporated fixtures and devices that reduce its water requirements in newly designed office buildings. GD’s Technology and Operations Centre (TOC) building in Markham, Ontario, captures rainwater from the roof and reuses it for landscape irrigation and cooling-tower requirements. The TOC’s innovative streetscape training centre, which simulates an urban community, also captures and retains rain water through a system of pervious pavers.

Water Disclosure

CDP, formerly the Carbon Disclosure Project, is an international, not-for-profit organization that provides companies and cities with a system to measure, disclose, manage and share vital environmental information.

We disclose information to CDP on GHG emissions, energy use and water use.

CDP scored and benchmarked our 2015 Water Response against companies within the energy sector globally.

We received a water score of “B”, which corresponds to a “Management” score level. The Management score level is awarded to a company that provides evidence of actions associated with good water management and the efforts taken to mitigate risks, making its risk assessments more robust and comprehensive, implementing a water policy, and integrating water issues into its business strategy.

The average CDP/Energy/Industry/Water Global 500 score was B-. We were among seven other energy sector companies that scored B, which was the highest score for the sector. The overall response rate for the energy sector for the CDP water disclosure was 22 percent, i.e. 23 companies out of 106 companies requested.

Waste Management

Our waste comprises recyclable materials such as paper, scrap metals, packaging materials and construction-related materials, as well as non-hazardous substances such as spent abrasive blast media, oily sorbents and soil.

We make every effort to reduce and minimize our waste volumes through measurement and management programs at our various facilities. We also try to find beneficial ways to reuse or recycle waste by-products. For example, GPP&ES recycles used lube oil from its compressor engines, spent activated carbon catalyst used in gas treatment, and spent catalytic converter catalyst used to control compressor emissions.

In Ontario, GD recovers and recycles waste polyethylene pipe, metal, tires, wood, electronic waste and furniture.  And, all of the GD offices have a green bin program for collecting waste organic materials. GD’s waste diversion rate for municipal waste was 54.6 percent in 2015, compared with 59.4 percent in 2014 and 55.3 percent in 2013.

In addition, property managers at our corporate and other office locations implement waste recycling programs that require employees to use recycling receptacles for materials such as paper, plastics, cardboard and batteries.  

At present, we are required to track and report on our waste management practices in some, but not all, of our regulatory jurisdictions. For example, the Alberta Energy Regulator requires us to track LP Canada’s waste within its jurisdiction. And, the Ontario Ministry of the Environment and Climate Change Hazardous Waste Information Network requires us to track GD’s liquid and solid hazardous waste and its liquid industrial non-hazardous waste.

Hazardous and Non-Hazardous Waste by Weight and Disposal Method

Over the past three years, the estimated total weight of GD’s hazardous and non-hazardous waste—by disposal method—was as follows:

Gas Distribution

Hazardous Waste/ Liquid Industrial Waste 2013 2014 2015
(kg*) (kg*) (kg*)
Recycled and Recovered 63,590 72,582 40,296
Incinerated 32,142 29,704 49,552
Deep-well Injection 6,855 10,410 0
Landfilled 452,077 1,991,514 717,456
Water Treatment 922,841 1,140,175 532,390
Solidification 0 434,995 456,464
Total 1,477,505 3,679,380 1,796,652
Non-Hazardous Waste 2013 2014 2015
(kg*) (kg*) (kg*)
Recycled and Recovered 1,888 0 0
Incinerated 0 1,550 0
Landfilled (placement, and daily cover/capping) 10,785,865 6,281,019 7,983,652
Water Treatment 330,240 378,107 70,450
Total 11,117,993 6,660,676 8,054,102

*assumed average density: 1 liter = 1 kg

The total weight of GD’s hazardous waste (including liquid industrial waste) and non-hazardous waste varies from year to year depending on the number of construction projects that GD completes.  GD’s year-over-year increase in hazardous waste in 2014 was due to an increase in work activities and to the fact that GD had replaced underground storage tanks at two locations. The table does not include GD’s hazardous waste volumes, but GD will report those volumes in Enbridge’s 2016 CSR & Sustainability Report. The weight of GD’s non-hazardous waste slightly increased in 2015 due to the higher volumes of contaminated soil that GD encountered, and to the fact that GD is not able to re-use contaminated soil as backfill.

Air Emissions Management

NOx, SOx and Other Significant Air Emissions

The major air emissions that our facilities release include carbon monoxide (CO), nitrogen oxides (NOx) and volatile organic compounds (VOCs). Other contaminants that they release, but in much smaller quantities, include sulfur dioxide (SO2), hydrogen sulfide (H2S), particulate matter (PM) and hazardous air pollutants such as n-hexane.

Our facilities are designed to ensure that air emissions from our operations are kept below regulated limits. In some cases, we have exceeded regulatory requirements and have installed technologies in our facilities that further reduce air contaminant emissions.

Reporting Criteria Air Contaminants

Criteria air contaminants (CACs) are a group of common air pollutants that are released through incineration, industrial production, fuel combustion and transportation vehicles. We have established management programs that define our roles, responsibilities and timelines for reporting our CAC emissions to various government agencies in Canada and the U.S.

We base our CAC emissions estimates on published emission factors applied to fuel use by equipment type. In the case of non-combustion sources, we estimate CAC emissions using modeling programs such as the U.S. EPA’s TANKS program. We also use some site- or equipment-specific emission factors.

In Canada, LP and GD track and report annual CAC emissions under the National Pollutant Release Inventory (NPRI). The CACs covered under the regulation include NOx, SO2, VOCs, CO and particulate matter. In the U.S., both LP and GPP&ES monitor and report on CAC emissions in compliance with state and federal regulations.

Liquids Pipelines – Within LP’s operations, the main source of VOC emissions is losses from storage tanks, while the main source of NOx emissions is combustion equipment.

Air emissions levels vary from year to year depending on a number of factors, including throughput of products at terminals, product composition, maintenance activities such as tank cleaning, implementation of pollution prevention projects and the amounts of fuel used in combustion equipment.

The tables below summarize LP’s CAC information reported in its jurisdictions:

Liquids Pipelines Canada

 (tonnes) 2012 2013 2014
NOx (as NO2) 120 125 123
VOCs 3,592 2,534 2,297
PM2.51 60 60 60
PM101 564 565 584
TPM1 2,179 2,179 2,145

The majority of particulate matter (PM 2.5, PM 10 and TPM) that LP reported under the NPRI program is due to road dust. Much smaller quantities of particulate matter are from stationary combustion sources.

Liquids Pipelines U.S.

(tonnes) 2012 2013 2014
NOx < 1 7 27
VOCs 638 675 685
PM2.5 < 1 0.6 0.6
PM10 < 1 0.6 0.6
TPM < 1 0.6 0.6
CO < 1 11 59

LP established an ambient air monitoring network to monitor the air quality in and around its tank farm at Hardisty, Alberta. The stations collect and monitor the air quality both continuously and on the National Air Pollution Surveillance schedule. In addition to the air monitoring stations, LP conducts semi-annual head-space air sampling on each storage tank to ensure emission-control devices are functioning.

LP is a member of the Strathcona Industrial Association (SIA), which owns and operates an air monitoring network in Edmonton and Strathcona County, Alberta. The stations continuously monitor the air quality around LP’s Edmonton Terminal.

LP is also a member of the Sarnia-Lambton Environmental Association (SLEA), a non-profit cooperative that comprises industries in southwestern Ontario. SLEA monitors ambient environmental conditions to assess the impact of its members on the local environment (air, water and soil). LP operates the Sarnia Terminal, which is within the jurisdiction of SLEA. 

LP has a rigorous maintenance program in place that includes regular inspections of emission control devices, and repair or replacement of them to ensure they meet regulatory criteria.

Gas Pipelines, Processing & Energy Services – GPP&ES is continually looking for opportunities to upgrade its gas facilities and pipelines in ways that contribute to its operational, environmental and safety goals. One example is acid gas injection, which uses advanced technology to compress acid gas, primarily H2S and carbon dioxide (CO2), and inject the gases into suitable underground reservoirs, thereby avoiding emissions to the atmosphere. In 2014, GPP&ES utilized two acid gas injection wells near our Aker Treating Plant in East Texas. In 2014, the facility injected more than 29,000 tons of CO2 and nearly 260 tons of SO2 that otherwise would have been emitted to the atmosphere.

GPP&ES reported the following criteria pollutant emissions in the three years in 2012, 2013 and 2014:

Gas Pipelines, Processing & Energy Services (tonnes) 2012 2013 2014
CO 1,926 1,783 1,399
NOx 2,795 2,766 2,319
VOCs 1,647 1,177 1,352
SO2 540 412 403

2014 totals include emissions data for GPP&ES’s interest in the Vector natural gas pipeline and Enbridge’s storage terminal located in Cushing, Oklahoma. Data from those assets were not included in prior-year totals.

Gas Distribution – In Canada, GD reports annual criteria air contaminant emissions under the National Pollutant Release Inventory (NPRI). GD calculates emissions using emission factors or site/equipment-specific data. The emissions that GD reports to NPRI depend on which facilities are above the reporting thresholds for each reportable substance. As such, they fluctuate from year to year.

In 2014, GD reported three facilities to NPRI versus only one in 2013. In 2013, one facility that normally would have triggered reporting was out-of-service, but was back in service during 2014. Additionally, a third facility had a higher run time than previous years, which pushed it over the threshold for reporting for particulate matter.

Gas Distribution (tonnes) 2014 2013 2012
CO 119 72 90
NOx (as NO2) 132 66 110
VOCs 30 27 16
PM 1.8 0.67 -

In 2012, GD’s PM emissions were not reportable.

Management of Ozone-Depleting Substances

We do not use Ozone-Depleting Substances (ODS) in our industrial processes, products or services, so this indicator does not generally apply to our business.


Gas Distribution (GD) has the largest fleet of natural gas vehicles in Canada.

Over the last decade or so, GD has converted 648 of its 853 fleet vehicles to run on natural gas. The majority of these vehicles run on both natural gas and gasoline, but some of them—mostly medium-duty trucks, which are normally diesel-fueled—run only on natural gas. Through this initiative alone, GD has reduced its GHG emissions by more than 500 tonnes of carbon dioxide equivalent per year.

GD has also reduced its fleet size by standardizing vehicle designs and building in versatility. For example, it has redesigned some of its trucks such that one truck can now perform three functions. In this way, only one truck is needed, whereas, as in the past, three were needed.

And, GD has installed a hybrid-power system that enables work trucks to operate AC and DC power tools and equipment from their batteries when their engines are not running. This system reduces fuel consumption and GHG emissions, along with vehicle idling, noise, and wear and tear.

Impact Mitigation

We are involved in a wide range of initiatives aimed at mitigating the potential impacts that our business has on the environment. We take a proactive approach at all stages of our work.

We conduct environmental assessments and implement industry-standard protective measures prior to conducting project-related work—and many operational activities—to address all foreseeable impacts.

We aim to prevent any spill, leak or release of petroleum products through proactive monitoring, inspection and maintenance. When we experience a spill, leak or release, we carry out emergency response procedures to shut down and isolate the impacted asset, notify the appropriate government and regulatory agencies, contain the substance as appropriate, and manage potential safety and environmental impacts. For more information, please see the Fitness of Enbridge’s Systems and Leak Detection and Emergency Preparedness & Response sections of this report.

Every year, we invest significantly in pipeline technologies that improve the fitness of our systems, leak detection and damage prevention capabilities. We also invest in emerging technologies, such as clean power and energy storage. For more information, please see the R&D and Innovation section of report.

GD provides incentives to customers—from homeowners to large industrial facilities—to encourage them to adopt energy-saving equipment and operating practices that reduce natural gas consumption. For more information, please see the Energy & Climate Change section of this report.