Enbridge believes it has sufficiently proven its Line 3 oil pipeline replacement project is needed in the state, the company said in documents filed Monday, countering a state agency that has repeatedly argued the wrong model was used to forecast oil demand.

In a response to requests for reconsideration made in May by the Minnesota Department of Commerce's Division of Energy Resources, Minnesota tribes and environmental groups, Enbridge said the Minnesota Public Utilities Commission had reviewed an appropriate demand forecast when granting the proposed pipeline its certificate of need in February and urged the PUC to deny the petition.

In May, the department said the PUC did not consider a long-range demand forecast because Enbridge instead submitted a pipeline utilization forecast that assumed demand would continue at 2016 refinery capacity.

"To the contrary, and as the (PUC) has always recognized, supply forecasts are critical to the evaluation of need for a crude oil pipeline. By definition, crude oil pipelines transport crude oil from a given starting point to one or several endpoints. If insufficient supply exists at the starting point, all of the downstream analysis in the world is pointless," Enbridge attorney Christina Brusven wrote. "Therefore, the (PUC) properly considered supply forecasts in its order."

Other parties, including the Red Lake Band of Chippewa, White Earth Band of Ojibwe, Honor the Earth, Youth Climate Intervenors, the Sierra Club and Friends of the Headwaters, also asked the PUC to reconsider its approval of Line 3.

The groups also argued the PUC should reconsider the pipeline because the COVID-19 pandemic has caused the demand for oil to drop.

Enbridge's system of pipelines across Minnesota transported 14% less oil in April because of the pandemic.

The PUC has until July 20 to either accept or reject the requests for reconsideration. If it rejects the petitions, parties can ask the Minnesota Court of Appeals to review the case.

The PUC voted 3-1 in February to reapprove Line 3’s certificate of need and route permit for the proposed 340-mile pipeline across Minnesota.

Enbridge still needs numerous permits before construction can begin on the Minnesota section of Line 3. The Canadian and Wisconsin sections are already in service.

Once complete, the pipeline will ferry 760,000 barrels of oil (31.92 million gallons) per day from Alberta, Canada, to the Enbridge terminal in Superior.