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Letter to County Board Members, Knox County

July 15, 2022

County Board Members
200 S. Cherry St.
Galesburg, IL 61401

RE:  Navigator Heartland Greenway CO2 pipeline

Dear Chairman Hawkinson,

The purpose of this letter is to make you aware of a commercial venture that will have a significant, and likely adverse, impact on Knox County and the 12 other Illinois counties affected by it.  The same letter is being sent to every member of the Knox County Board, the Mayor of Galesburg, and several Knox County township and municipal governments.

The commercial venture I want to make you aware of is the Navigator Heartland Greenway Pipeline project, a private for-profit venture that proposes to construct a 1,300-mile liquid CO2 pipeline through five states and 13 Illinois counties, including Knox, Henry, and Fulton.  It aims to capture industrial CO2, reduce it to a supercritical liquid, and transport it under high pressure to an underground sequestration site (i.e., dumpsite) in Christian County, Illinois--a scheme my best friend from law school likens to trying to put the methane back in the beans after eating a bowl of chili.  Although Navigator is trying to disguise its proposal as eco-friendly, the real incentives behind the project include collecting 45Q tax credits from taxpayers (and possibly Low Carbon Fuel payments from California as well), and/or providing a source of liquid CO2 for use in enhanced oil recovery.

By way of background, I am a retired U.S. Marine Corps judge advocate, a member of the State Bar of Texas, and a member of the bar of the Supreme Court of the United States of America.  I am the fourth generation to live on a Knox County farm that has been in my family for over 105 years.  We are located in Truro Township, on the edge of the Spoon River bottom.  Our ground, which the Heartland Greenway Pipeline wants to use as its right of way, is classified as highly erodible.

On my family’s farm, the Heartland Greenway pipeline company proposes to dig a trench seven feet deep, and 15 feet wide, through our fences, across a flowing stream, down a slope that drops 100 feet in less than 300 yards, through multiple terraces, drain tile, a grass waterway containing two parallel tiles, and, finally, a riser and tile at the edge of one of our fields.  Ironically, because it's highly erodible, we're restricted by regulation from using certain types of tillage equipment on the same ground the pipeline company wants to dig up.

The pipeline company has made it clear that it intends to ask the Illinois Commerce Commission for eminent domain authority to take private land for right of way easements.  The issue came to a head in May 2022 when the company’s land agent began calling Knox County landowners, requesting permission to conduct surveys across their property.    

Because companies like Navigator make it a practice to keep local governments in the dark as to their actions for as long as possible, it is imperative that you quickly become familiar with two issues related to the Heartland Greenway Pipeline: (1) its impact on Knox County infrastructure; and (2) the potential safety hazards associated with having a high-pressure CO2 pipeline running through the county.  You also need to understand the pipeline’s adverse impacts on Knox County landowners, particularly farmers, all of whom are your constituents.  These impacts include productivity loss, damage to drain tile and erosion control structures, damage to topsoil, damage to fences, destruction of trees, and restrictions on future use of land in the pipeline right of way.

Navigator’s proposed right of way map indicates the Heartland Greenway Pipeline will cross numerous existing transportation rights of way in Knox County, including state and U.S. highways, county and township roads, and two major rail lines.  It will also cross the Spoon River, as well as numerous creeks and streams.  Each of these will have to be crossed by means of digging or boring.  The disruption caused by the construction activity required to accomplish this, and the damage to roads from heavy equipment, will be immense, and the impacts long-lasting.  Repairs to correct erosion and settling at points where the pipeline intersects public roads will eventually become costs  that have to be absorbed by the taxpayer.

In addition to the above, the pipeline will encounter numerous underground utilities, including water and sewer systems, underground power lines, fiber optic cable, and existing oil and natural gas pipelines.  If these are damaged during pipeline construction, they will never be as good as they were before--no matter how good the repairs to them.  If an oil or natural gas pipeline is damaged during construction, the results could be catastrophic.

In addition to its effects on infrastructure, the Navigator Heartland Greenway PIpeline will pose multiple safety hazards.  These hazards will be particularly significant in Knox County due to its rural nature and the lack of first responders trained and equipped to deal with the dangers posed by CO2 pipelines.

The landowner information packet I received from the Heartland Greenway Pipeline company contains the following: “We will have enhanced monitoring systems in place 24 hours a day, 7 days a week, 365 days a year.”  It goes on to claim, “A state-of-the-art leak detection system is constantly monitored by qualified operators to ensure safe and reliable transportation of the CO2 at various points along the system.”

Note: In oil pipelines, state-of-the-art systems can only detect leaks greater than 1%.  Detecting CO2 leaks is much more difficult because of the impact of temperature on the density of CO2.  A CO2 pipeline rupture, especially one occurring at night, can kill or injure humans and animals in its vicinity long before Heartland Greenway’s “state-of-the-art leak detection system” becomes aware of it and the company reacts.  When emergency response times are added to the time required to detect a CO2 pipeline leak, the potential for a mass casualty event is enormous.  People and animals can be dead long before Heartland Greenway even knows there is a problem with its pipeline.

As a result of several past family medical emergencies, my personal experience, in my area of Knox County, is that it takes at least 35 minutes for police and ambulance personnel to arrive on scene from the time a 911 call is placed.  Thirty-five minutes is a long time to breathe a deadly gas without being rescued.  

My Heartland Greenway landowner information packet contains the following so-called assurance: “Additionally, we install strategically placed mainline valves, or MLV’s, that further allow the company to operate the pipeline safely and reliably.”  This raises several questions.  Will the valves close automatically upon detecting a pressure loss in the pipeline?  Will Heartland Greenway have redundant communications capabilities and power supplies?  Just how dangerous would a CO2 pipeline in Knox County be?

CO2 must be under tremendous pressure to be transported in liquid form.  In some ways, it behaves like anhydrous ammonia, a commonly used agricultural fertilizer stored and transported in supercold liquid form.  In other respects, it behaves in ways much different than anhydrous ammonia.

At room temperature, anhydrous ammonia is stored at about 100 psi.  Liquid CO2 is stored at between 1,072 and 2,500 psi--astronomically greater pressures.  And the impact of an anhydrous ammonia leak is much different than a CO2 leak.  Anhydrous ammonia is lighter than air; CO2 is not.  In the event of a pipeline rupture, CO2 will rapidly boil out of the pipeline into a heavier-than-air gas that travels along the ground and settles in low lying areas.  It can travel at speeds in the neighborhood of four miles per hour, and cover several hundred yards in under a minute.  It can be lethal at distances over a mile from the point of rupture.  And, unlike natural gas, CO2 has no warning odor.  It robs the air of oxygen.  It can kill you in your sleep before you ever have a chance to escape from it.

At concentrations between 2 and 10%, CO2 causes nausea, dizziness, headache, mental confusion, increased blood pressure and respiratory rate.  Above 8% nausea and vomiting occur.  Above 10% humans and animals can suffocate and die within minutes.  Moisture in the air can cause carbonic acid, an eye irritant, to form.

All of these dangers were revealed in February 2020 when a liquid CO2 pipeline ruptured at night near Satartia, Mississippi.  Although the rupture occurred half a mile from houses, residents were left foaming at the mouth, gasping for air, nauseated, and disoriented.  300 were evacuated; 45 were hospitalized.  Those who tried to escape in vehicles discovered another fact about CO2 pipeline breaks: gasoline and diesel engines cannot operate in the presence of CO2.  Once CO2 displaces the oxygen needed to burn fuel in the engine, the engine stalls.  In the event of a CO2 pipeline rupture, escape will have to be on foot or in all-electric vehicles.

Another thing: not only will people not be able to drive out of the gas cloud from a ruptured CO2 pipeline, emergency vehicles won’t be able to drive into it.  (Note: the gas cloud will also contain solid CO2--i.e., dry ice--at temperatures of -109 degrees fahrenheit or below; think about what direct contact with dry ice would do to one’s eyes and respiratory system!)  And forget about Life Flight helicopters.  They will stall in the presence of CO2 for the same reason a car or truck will.  As we used to say in the Marine Corps, when the main rotor on a helicopter stops turning, the helicopter immediately assumes the aerodynamic properties of a large rock.

To respond to a CO2 pipeline leak, first responders will need electric ambulances and emergency vehicles, as well as large supplies of self-contained breathing apparatus (SCBA), which can cost over $3,000 per set.  Who is going to pay for these items?  Does Knox County have money for this?  Can the fire protection districts in the county afford it?  What about people living near the pipeline right of way?  Are they supposed to equip themselves with SCBA, at $3,000 dollars a pop?  Will the Navigator Heartland Greenway Pipeline company  pick up the tab?  Has it even offered to?  

To put it bluntly, you’re on your own if you’re too close to a CO2 pipeline break.  For some reason, the landowner packet I received from Heartland Greenway fails to mention the hazards and concerns I’m bringing to your attention.  Probably an oversight on the company’s part.

Although Heartland Greenway claims it will monitor its pipeline 24/7, one fact is clear: in the event of a rupture, all the liquid CO2 between the pipeline shutoff valves on either side of the break will be released, even after the valves are closed, posing a lethal hazard to nearby humans and animals.  Even if the shutoff valves are only a mile apart, the amount of CO2 released from a one-mile length of 24-inch diameter pipeline would be tremendous.  (Note: Heartland Greenway announcements have shown distances between shutoff valves of up to 30 miles.)

Considering the risks associated with its proposed liquid CO2 pipeline, as a member of the Knox County Board, or other government official, you should be asking the Navigator Heartland Greenway Pipeline company why it isn’t providing nearby residents with SCBA and electric cars.  You should also ask it if it plans to donate electric emergency vehicles and SCBA to governmental entities along its right of way.  Will it pay to train first responders to handle CO2-related mass casualty events?  Remember: there are only about 5,000 miles of CO2 pipeline in the United States, most of which are only a few miles in length and serve single customers.  Navigator, which has never built a liquid CO2 pipeline before, and has zero experience with them, plans to build a 1,300-mile-plus CO2 pipeline to serve multiple customers.  Are you willing to trust the welfare of Knox County and its residents to a private company, headquartered in another state, motivated solely by a desire to make money--at the expense of Illinois and Knox County landowners--without first conducting a detailed inquiry into its proposal?  

As a government official charged with protecting the welfare of Knox County, a township, or municipality, I encourage you to take advantage of the Coalition to Stop CO2 Pipelines‘ request to address the Knox County Board for the purpose of: (1) providing information about the Navigator Heartland Greenway Pipeline project; and (2) to suggest adopting a one- to two-year moratorium on CO2 

pipelines to allow time to prepare zoning regulations that maximize protection for local communities, residents, businesses, institutions, farmers, and livestock.


Colonel, U.S. Marine Corps (Ret)
Attorney at Law
State Bar of Texas: 06891500

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