Midwest CO2 Pipelines Climate Impacts


As of June 2022, three large CO2 pipeline systems are proposed for the Midwest. The map below is speculative based on the facilities currently signed on, because the pipeline corporations have not finalized their routes yet. There is a clear lack of central planning and regulation for these systems overlapping each other across the region.

Summit’s proposed network would connect 33 mostly small ethanol facilities and a proposed fertilizer plant to a carbon sequestration site in North Dakota. They have partnered financially with North Dakota’s largest oil driller, Continental, and signed a carbon storage deal with Minnkota, a coal-heavy electric utility.

Navigator’s proposed network would connect 36 mostly larger ethanol and fertilizer facilities to a carbon sequestration site in Illinois. ADM/Wolf’s proposed pipeline would connect three massive corn processing facilities (ethanol and other products) to the same sequestration area.

Enhanced Oil Recovery

Captured CO2 is most commonly used for enhanced oil recovery (EOR). EOR has been used at or very near the proposed sequestration sites of each project, in both North Dakota and Illinois.

The International Energy Agency (IEA) and industry groups claim that this process can produce “carbon negative oil”. However, their own methodology indicates that conventional EOR results in 1.8x more carbon emitted than is sequestered. They also claim that “advanced EOR+” methods can result in slight net reductions in carbon emissions, but they are evaluating these scenarios while assuming that all oil demand must and will be met, and that EOR oil mostly displaces other oil in the market.

Image from IEA Reports linked above.

In reality, there is a finite amount of oil on Earth, and much of it is only accessible by using EOR. While CO2 injection is not the only major method of EOR, any restriction in supply of CO2 used for EOR would increase the likelihood of more oil remaining in the ground. Research shows that over 60% of oil & fossil gas must remain in the ground in order for us to meet the goals of the Paris Climate Agreement.

Regardless of how advanced the EOR process is, there are better ways to do carbon sequestration (i.e. chemical storage or mineral storage) that don’t involve oil, and also have less risk of CO2 leakage. Speaking of leakage, CO2 pipelines pose tremendous risks to environmental and human health from rupture and leakage, which we won’t elaborate on here, but this piece on the Satartia Incident is essential reading.

Ethanol Lifecycle Emissions

The Midwest CO2 pipeline systems allow the ethanol, fertilizer, and potentially other polluting industries to collect tax credits for CCS, thereby subsidizing and enabling their continued operation. We attempt to represent the systems and feedback loops with a flowchart below:

Flowchart created by Science for the People – Twin Cities, 6/23/22.
Green = positive relationship, red = inverse relationship.

Ethanol plant owners and operators who have signed on with a CO2 pipeline corporation have said that these CCS tax credits are necessary for them to continue to compete and operate in today’s markets. Ethanol producers are literally trying to stay in business by partaking. A Summit executive stated a goal of providing “longevity for the community’s ethanol plant.” The Ethanol Industry as a whole recognizes the need for CO2 pipelines to keep them competitive.

Yes, an ethanol facility can lower its carbon footprint by doing CCS via CO2 pipelines, but if those systems enable the continued existence of the ethanol industry, then they will overall be bad for the climate. This is mainly due to global land use change, fertilizer use, and the fuel market rebound effect.

The 68 ethanol plants that have signed onto the 3 Midwest CO2 pipeline systems thus far total 10.7 Million metric tons of annual CO2 emissions (3 year average), but their full capacity lifecycle emissions are calculated at 72.5 MMT/yr. If even 15% of these ethanol plants (in terms of production capacity) can attribute their continued operation to CO2 pipelines and tax credits, then that will mean CO2 pipelines cause a net increase in GHG emissions.

Pipeline SystemEthanol CO2 Captured (MMT/yr)Total Ethanol Emissions (MMT/yr)% Emissions Sequestered

Lastly, there are several critical opportunity costs of growing corn for ethanol in the Midwest. An acre of solar panels in Iowa can produce 34 times more energy as an acre of corn grown for ethanol would. Maybe even 100 times more. Ethanol offsets just 6% of U.S. gasoline use, and just a 2 mpg increase in fuel economy would offset as much. Growing plants for fuel instead of food is worsening the global food crisis, in addition to the climate crisis.


Both EOR and ethanol lifecycle emissions on their own are reason enough to declare that CO2 pipelines are very likely to cause a net increase in GHG emissions. When we combine those two main factors, and add the electricity sector emissions from pipeline compressor stations, it’s not even close. Obviously, anyone in the Midwest who cares about climate change should oppose these CO2 pipeline systems.


Let’s clear the air on how the Line 3 tar sands oil pipeline really impacts Minnesota:

The ongoing Line 3 construction is a simple replacement project.The new Line 3 takes a new route through previously undisturbed waterways, and would more than double its current capacity.
We need to double the capacity of Line 3 to meet demand for oil.Enbridge tried to use a supply forecast instead of a demand forecast. Their mainline volume has actually decreased in the past year (S&P).
Line 3 is necessary because we will keep using oil for a long time.Even conservative projections from the IEA forecast oil demand growth to end sometime this decade.
If this pipeline isn’t built, there will be thousands of dangerous oil trains going through Minnesota.There’s no evidence that it’s possible to transport 915 kbpd of oil by rail thru MN’s rail network. Overall tar sands oil transport by rail was much lower than that in recent years.
Building a new pipeline would protect the environment and the economy long-term.A newly built Line 3 would transport tar sands oil long past the time of economic unviability. This infrastructure lock-in would lead to increased costs and emissions for Minnesota.
The new Line 3 would be much safer than the old Line 3.There is no evidence for this claim. Safety is not related to age as much as it is to operator commitment to safety, which Enbridge lacks.
The permitting process for Line 3 was scientific and robust.The Line 3 permitting process was flawed on many levels, and the Walz Administration failed to take responsibility for it.
Line 3 creates many local jobs for hardworking Minnesotans.Enbridge promised over 75% local jobs, but has only delivered on 23% of them. The vast majority of these jobs are temporary and dangerous.
Line 3 is boosting local economies in Northern Minnesota.Enbridge went to court to avoid paying taxes in Minnesota, leading to a ‘worst case scenario’ for 13 Northern Minnesota counties.
The influx of pipeline workers is good for local communities.Enbridge workers were caught in child sex trafficking rings in Northern MN. Pipeline construction causes the MMIWR epidemic.

Line 3 Hot Potato: Permit Process Failure and what we can do about it.

This video follows the broken process of Enbridge’s Line 3 tar sands oil pipeline in northern Minnesota. The issue and permitting of Line 3 has been a “hot potato” between Enbridge and different federal and state regulatory agencies. A flowchart and sources for all the facts cited in the video can be found below our statement of solidarity.

Despite massive public opposition to the project, Enbridge started construction in late 2020. To support the fight against Line 3, please share and follow the organizations through this link tree: https://linktr.ee/stopline3​, sign up to be involved and support the movement in many ways (near and far!): http://bit.ly/2NWQdxs

We are organized around the principle that science is a set of tools that can and should be used to advance human and environmental justice, rather than corporate profiteering resulting in ecocide and genocide. Acting on this principle has brought us into the Line 3 struggle and the fight for Missing and Murdered Indigenous Relatives, where powerful state institutions and actors use the veneer of science to shield themselves from accountability, while failing to take action consistent with what we know about the science of climate, land, and water. Governor Walz justifies his lack of action by saying he’ll listen to “science and the data” — and the Science for the People-Twin Cities Chapter is committed to demonstrating that the science and data clearly show we must reject Line 3. We recognize that the coordination of scientific research to support the movement against Line 3 does not add new information about the devastating impacts of this pipeline, but instead supports and upholds the knowledge held by the original caretakers and stewards of this land, the Dakota and Anishinaabe peoples. Our focus is to articulate the failures of the regulatory process, use our expertise to support legal challenges to permits, coordinate with and support community organizations, and participate in direct action and protest.

Black arrow = pushing off responsibility to another entity. Red arrow = putting constraints on another entity.


  1. Governor Walz is at the center of this game of hot potato, but he rarely took any responsibility for this disastrous pipeline, making weak statements, and going back on his promises. He left it to the State Agencies to make strong statements on it, yet he is ultimately responsible for the actions of all Executive Branch State Agencies. He didn’t, and still doesn’t listen to his Lieutenant Governor, Peggy Flanagan, who has consistently opposed Line 3. He voted for KXL as a Congressman.
  2. Walz appointed a former corporate executive, Laura Bishop, to lead the MPCA.
  3. Walz appointed multiple Commissioners to the PUC who have voted in support of Line 3. Commissioner Sullivan previously supported Line 3 back when he was Deputy Commissioner at the DOC.
  4. Governor Walz could have appointed a new Commissioner to follow in Steve Kelley’s footsteps, or instructed the Acting Commissioner to maintain the DOC’s lawsuit regarding Line 3. Instead he continued the trend of undermining the DOC’s decision making.


  1. The Trump Administration designated pipeline workers as essential during the pandemic. Governor Walz via the MN Department of Employment and Economic Development (DEED) chose to go along with this instead of maintaining the previous policy for Minnesota..


  1. The Minnesota Department of Health (MDH) in issuing their COVID-19 guidelines cited DEED/Walz’s previous decision to designate pipelines as essential. Consequently, Enbridge’s compliance plan is inadequate.


  1. The Minnesota Pollution Control Agency (MPCA) in part cited the previous decision from the PUC as justification for approving the Line 3 permits.
  2. The MPCA also inhibited the judicial branch from robustly evaluating the contested case hearing.
  3. The Trump Administration relaxed environmental regulations and reporting during the pandemic. The MPCA chose to follow this lead, instead of diverging from them. MPCA Commissioner Kessler in December 2021 blamed the “crappy” Clean Air Act and Clean Water Act for not being able to deny permits for Line 3.


  1. The Minnesota Public Utilities Commission (PUC) cited that the main reason for granting the Line 3 Certificate of Need was the fact that the existing Line 3 is degraded, and vulnerable to polluting the environment. This reason is clearly within the realm of concern of PHMSA, the MPCA, perhaps the DNR, and something that shouldn’t have been allowed to happen in the first place.
  2. The PUC also claimed they were prevented from ordering the existing Line 3 to shut down due to current Minnesota laws (which are obviously set by the State Legislature, and the Governor), and federal laws, that authorize PHMSA as the regulator over pipeline safety.
  3. The PUC also punted the decision on whether to grant a stay of construction over to the courts.
  4. The PUC said they couldn’t grant a stay on construction because going against Walz/MDH’s COVID-19 Emergency Orders would be “treasonous.”


  1. The Minnesota Department of Commerce (DOC), is a party to many PUC cases. Under the strong leadership of Commissioner Steve Kelley, they filed a lawsuit against the PUC’s approval of Line 3, due to lack of proof of demand for the pipeline and its oil. After his departure, the DOC declined to take a position on the request to the PUC for stay of construction on Line 3.


  1. MN Attorney General Keith Ellison represented the DOC in their lawsuit against the PUC, however he signed the letter that took a stance of neutrality on the request for stay of Construction on Line 3. He chose not to file an injunction in the Courts.


  1. DOC Commissioner Kelley was fired by the MN State Senate, in large part due to the lawsuit regarding Line 3. Every Senator that voted against him was a Republican or a former Democrat-turned-Independent.
  2. The DOC’s Division of Energy Resources and the PUC have also historically been underfunded / understaffed in recent years – this can largely be attributed to the MN Legislature.
  3. Meanwhile, the Office of Legislative Auditors found in their report on the PUC and Public Engagement that the PUC had violated the law in their process. (Summary Report).


  1. The US EPA implemented a rule that limited States (MPCA) from denying 401 permits for reasons other than water quality and imposed a 1 year deadline for decision. Note: The Executive Order on Climate Change signed by President Biden in the first days of his administration removed much of the fossil fuel-favoring policies of the previous administration. This revealed that the MPCA was too passive in following the Trump administration’s lead in recent months.
  2. The Consent Decree issued by the Federal Government to Enbridge required them to seek a replacement pipeline for their Line 3. While Enbridge has not stopped the PUC from believing they must order replacement of their Line 3 pipeline for safety reasons, that decision is not actually within their jurisdiction (as that is the sole authority of the pipeline company as regulated by PHMSA). The Consent Decree orders that Enbridge run their pipeline at the reduced pressure until they can secure (through permitting with all proper reviews and analyses) a replacement. Else, they were required beginning in 2017 to perform much more stringent inspections in order to continue running current Line 3 (which reduces their carrying capacity even further as inspections require downtime).


21. Commissioner Strommen cited the PUC’s granting of a Certificate of Need, and the MPCA water permit as why they couldn’t deny Enbridge’s permits.

22. Commissioner Strommen cited a lack of new legislation as why they couldn’t deny the permits.