Five ingredients for complete environmental review of Keystone XL tar sands pipeline - one is climate

The U.S. State Department has recently indicated that it will issue a Supplemental Environmental Impact Statement (EIS) for the proposed Keystone XL tar sands pipeline “in the near future.” While TransCanada has asked for a rubber stamp process than only evaluates a minor route change in Nebraska, concerned Americans and the environment community have made their expectations of the environmental review process clear. In July, NRDC joined a coalition of environmental organizations submitted comments explaining the need for a broad environmental review for Keystone XL to address significant changes in the project, new information, and address gaps in the prior review. NRDC and 350.org have also released a list of the top five issues that the new environmental review should cover. Fortunately, State has already committed to consider all relevant issues – specifically including climate change.

If the State Department honors its public commitments - which we expect it to do - the contents of the SEIS for Keystone XL should not be a surprise and will include a rigorous consideration of the following issues:

1. Keystone XL will increase carbon pollution.  A critical part of the environmental review is to consider the increase in greenhouse gas emissions from the Keystone XL pipeline. Keystone XL packs a wallop while it comes to climate emissions. The Environmental Protection Agency (EPA) estimates that by pipeline 830,000 bpd of tar sands instead of conventional crude, Keystone XL will increase annual U.S. CO2 emissions by up to 27 million metric tons – the impact of adding about 5 million cars on the road. Over the project's 50 year lifespan, that's 1.35 gigatons of increased carbon emissions. In addition, new research shows that tar sands development is causing significant additional CO2 emissions from Alberta’s peatlands and destroying carbon sequestration capacity in the Boreal Forest. Meanwhile, regulations promised by Alberta and Canada to mitigate these emissions haven’t materialized.

Moreover, Keystone XL is a necessary step for the tar sands industry to realize its goal of tripling production by 2030, or 6 million barrels a day - a goal which the International Energy Agency's analysis shows to be incompatible with a global plan to address climate change. State must consider how Keystone XL will significantly increase emissions and lead to expansion of tar sands production all evaluated in context of our nation’s long term climate goals.

New information demonstrates Keystone XL will expand tar sands production

Previously the State Department assumed that even if Keystone XL weren't built other pipelines would enable tar sands expansion to occur. The last year has demonstrated that assumption is deeply flawed. Recent events have shown that proposed alternatives to Keystone XL in Canada that are increasingly unlikely and that Keystone XL is critical to unlocking future tar sands production.

Enbridge’s proposed Northern Gateway tar sands pipeline through British Columbia to the Canada’s west coast - once considered as inevitable – is now considered by both proponents and opponents as dead on delivery. Commentators are writing posts such as You heard it here: Northern Gateway is dead and former supporters now suggest Enbridge offers a lesson in failure in op-eds like Dead Pipeline Walking. Even Canada’s pro-pipeline Harper government is dialing down its support for the toxic pipeline project.

“I personally don’t think Northern Gateway will go through anytime soon or if it ever will. There’s just too much politics in the soup and there are too many environmental concerns in the soup and there’s aboriginal rights in the soup and that makes for a pretty unsavory soup.” Roger McKnight, senior petroleum adviser at En-Pro International Inc., Sept. 10, 2012

In addition, Enbridge’s proposed tar sands pipelines to Canada’s east coast, always contentious, has run into a serious roadblock called Quebec. The new Premier of Quebec has recently voiced opposition to plans to ship tar sands in pipelines through his province. Experience shows provincial opposition can end unpopular projects despite federal support… while approving pipeline plans may be an issue of federal jurisdiction, providing tar sands pipeline pump stations with electricity is a matter of provincial jurisdiction.

Evidence that Keystone XL would lead to tar sands emissions

Keystone XL’s impact on future tar sands production is already demonstrated by the fact that in its absence, tar sands producers are mothballing new projects and cutting billions in investment. Here are just a few examples of how lower U.S. oil prices, constrained pipeline capacity and growing public opposition to tar sands expansion are affecting industry’s expansion plans:

• An August 2012 CIBC World Market Report forecasted long term growth in tar sands production would slow to half the pace currently projected by industry.
• Suncor has abandoned a plan to produce a million bpd by 2020, saying it would apply “rigorous scrutiny” to three of its most important new oil sands projects, Fort Hills, Voyageur, and Joslyn.[1]
• Canadian Natural Resources Ltd has cut capital spending in 2012 by $680 million from its Horizon tar sands project.
• Citing market conditions and pipeline constraints, CIBC World Markets Inc. recently reported that the tar sands industry “will push back long-term targets and raise questions regarding project viability”

“Oil sands was more of a compelling story even a year ago than it is today. Now, if you've got a billion dollars to spend, you've got to be thinking about all these threats and new opportunities and how you're going to spend your money. [Its] a big rethink of capital allocation.” Peter Tertzakian, Chief Energy Economist with ARC Financial Corp, Aug. 10, 2012

2. New information on TransCanada’s poor safety record and the safety of tar sands pipelines should inform environmental review. TransCanada is currently under a sweeping investigation by Canadian regulators after they confirmed the account of a whistler-blower documenting repeated violations of pipeline safety regulations by the company. This is the latest in a long series of accidents, shutdowns and pipeline safety infractions that have hounded TransCanada. TransCanada has built two pipelines in the United States in recent years – Keystone I had 14 leaks in its first year of operation and had to be shut down by regulators at one point, and its Bison pipeline exploded. Needless to say, TransCanada’s poor track record constructing pipelines should be considered in the State Department’s analysis.  

“It is a recognition that there was something really wrong with TransCanada. Because in my letter to Russ Girling, I told him that [TransCanada’s] business plan doesn’t match the NEB regulations.” Evan Vokes, Former TransCanada Metallurgist

 Moreover, experiences from the $800 million Kalamazoo spill have shown that tar sands spills are significantly more damaging than conventional crude spills. The environmental review should consider TransCanada’s plans, policies, and practices and evaluate the impact of tar sands spills along sensitive rivers and aquifers along Keystone XL’s route.

3. The Keystone XL pipeline is still a pipeline through America - not to it. TransCanada’s application proposes a fundamentally different pipeline that will require a fresh and independent environmental review that looks at climate and other impacts and whether we even need this pipeline at all to meet our energy needs.  Keystone XL is a tar sands pipeline through the United States, not to it. Industry has made it clear that Keystone XL is part of a plan to find markets for tar sands outside of the United States — while America’s communities, land and water bear the risk. The environmental review should evaluate the tar sands pipeline in context of industry’s plan to divert tar sands from the Midwest to the Gulf Coast where it can be refined and exported.

4. Keystone XL’s impact on refinery communities. Low-income communities will bear a disproportionate share of the contamination of air and water created by spills along the route of Keystone XL and refinery emissions from processing dirty tar sands. The review should evaluate which communities will be adversely impacted by Keystone XL.

5. The public needs a fair opportunity for their voices to be heard. Given the serious environmental impacts from the pipeline, the public should be given sufficient time to comment on the draft of the environmental review. An appropriate period would be 120 days, with the State Department holding public hearings along the pipeline route. Then, the State Department should produce a final environmental review that takes the public’s comments into consideration.

President Obama rejected the Keystone XL tar sands pipeline earlier this year because its risks had not been fully evaluated. We all know the ingredients of a complete SEIS. Now is the time for the State Department provide one.