If you ask me how much pipeline risk I’m willing to accept, my answer is “it depends on the context”. Do you want me to say what risks I’m personally willing to take? Do you want me to say what risks I’m willing to ask others in my community to take? Do you want me to tell you whether I accept that the risks have been sufficiently accounted for in a project? Those are all questions about acceptability of risk, but each has a different answer.
In this blog post, I want to explore these different ways of thinking about risk in the context of the Dragonpipe (the Mariner East pipeline system). Examining these ideas can have implications for our individual decisions, for decisions about our communities, and for decisions about laws, regulations, and legal responsibility.
Individual risk: Am I, personally, willing to live here? Individual risk is the type of risk that has been estimated in the pipeline risk assessments that have been done in our area so far. It is the risk to an individual person at a given location relative to the pipeline.
Individual risk is calculated based on the likelihood of a given size of release (using industry statistics) and the potential for death of an individual in a given location from that release.
That risk can be compared to the risks an individual tolerates in daily life (driving a car, going up and down stairs, etc.). It is only useful in answering the question “are you, personally, willing to accept this level of risk to your safety?” You might find it helpful in determining whether to buy a house in a specific neighborhood, for example. The Citizens’ Risk Assessment and the Delaware County risk assessment are both based on individual risk.
Societal risk: Should my community accept this risk collectively? A societal risk assessment looks at the impact of a project on the risk to the community as a whole. Might a lot of people be affected by a single incident? How does it affect our kids? Our seniors? Our emergency services?
In this case, the risk is calculated by figuring out the risk to everyone who could be affected by all the different leak possibilities in each location along the pipeline. The result is a graph showing, for each number of deaths, how likely an accident involving that number of deaths would be. Again, industry leak statistics are used.
Societal risk needs to be considered separately from the risk to individuals. I, for example, am much more willing to take a risk for myself than I am to put hundreds of people in schools and retirement homes at risk.
Conducting a societal risk assessment is more expensive than an assessment of individual risk because it requires detailed data on where the local population is concentrated, including changes in the course of the day and times of the year. For example, the threat to a school is greatest during class hours, and it may be minimal in the summer. But societal risk assessment needs to be done because it is far more important to most of us than the individual risk is.
Pipeline supporters have been saying that it is useless to measure societal risk because the US has no numerical standards for an “acceptable” level of societal risk. That statement is true, but it is not really relevant for two reasons:
- The US has no numerical standard for individual risk, either, and yet individual risk analysis has proven very helpful.
- Many other countries do have numerical standards for societal risk, and we can use them as a guide. It is quite reasonable for a community (or a state for that matter) to establish similar limits. (I hope to explore how other countries use these standards, and how we could apply them here, in a future blog post.)
And of course there are societal risks we do take seriously here in the US despite the lack of numerical standards. We take steps to prevent school shootings, for example, even though the individual risk of being shot in a random act of violence is very low. Individually, we are willing to risk being in places where a shooting could occur, but as a community we are not willing to accept this risk for our children. And I don’t know of anyone who claims that being concerned about the risk of school shootings is “useless” because the US does not have a numerical standard for that risk.
Both “individual risk” and “societal risk” calculations make the assumption that there is a numerical value that represents an acceptable level of risk, and that all we need to do is make sure a given project stays below that number. But is that the best way to think about risk? What if there are two ways to do a project, both meeting the numerical criterion, but one is far safer than the other? Shouldn’t we choose the safer one? That is what some countries, including Australia, are trying to accomplish, by analyzing worst-case scenarios.
Worst-case risk: Is this project being done in a way that minimizes what the consequences could be in the worst possible case? Australia is one of the countries that takes a completely different approach to the issue of pipeline risk. It requires the company doing the project to determine what could possibly go wrong in any possible worst case, and then to show that its top management has chosen to proceed despite the potential consequences from that worst case.
If Sunoco were proposing to construct the equivalent of the Mariner East system in Australia, they would have to ensure that CEO Kelsey Warren (and his top advisors) was aware that a pipeline rupture along the route that had been chosen could result in hundreds—or perhaps thousands—of deaths. To then proceed without considering alternatives would open top management to legal jeopardy. Even in an organization with a “wild west” mentality like Energy Transfer, the formal presentation of that information would probably trigger a management discussion about alternative routes with less risk.
There is no reason why the US (or the Commonwealth of Pennsylvania) could not adopt the same type of pipeline requirements as Australia. And, not surprisingly, the Australian approach works. Australia has far fewer pipeline accidents in proportion to its miles of pipeline than the US.
Sunoco, in its planning for the Dragonpipe, obviously didn’t worry about minimizing worst-case consequences. If it had, it would never have chosen a route that went through dense urban centers and adjacent to schools and retirement homes, even though shifting the route by a mile or two would avoid these entirely. In fact, in the agreement that settled Sunoco’s dispute with Clean Air Council and two other plaintiffs, it agreed to consider other routes, but it never did so.
Legislators: we need a worst-case risk approach to pipeline projects. I would argue that we need to implement a “worst-case risk” approach in Pennsylvania, and ultimately nationwide. The public needs to know that top management at any company undertaking a risky pipeline project is fully aware of the worst-case risks involved and has made an explicit decision that it will move ahead all the same. The public, as well as company management and shareholders, would have a clear picture of the moral and legal issues raised by giving the go-ahead to the project. The discipline involved in this approach will lead to better decisions about routing and construction—and in some cases, about the wisdom of undertaking a given project in the first place.
A final note: where’s the balance? I cannot end this blog post without reminding everyone of the implicit tradeoff that got us to this point. “Risk” is not normally measured in isolation. In most contexts, it is balanced against a potential “reward”. Normally, those bearing the risk do so because they perceive that the reward will outweigh the risk.
The Dragonpipe is not a “normal” situation, however. The public is taking on almost all of the risk, while receiving almost none of the reward. Sunoco shareholders and European plastic makers (and apparently some politicians) are being rewarded. The rest of us are not being asked if this is a fair tradeoff; it is being imposed on us. Where are the politicians and regulators who are supposed to take care of the public’s interest? They are missing in action. This must change.