The public comment period on the draft environmental impact statement (DEIS) for the proposed Keystone XL tar sands pipeline came to an end on July 2, 2010. The Natural Resources Defense Council joined with the Sierra Club, the National Wildlife Federation, Earthjustice, the Western Organization of Resource Councils and Plains Justice in filing joint comments. Our comments provide detailed reasoning for what we have been saying publicly for some time now about the pipeline and about the draft environmental impact statement: the Keystone XL tar sands pipeline should not be built and the draft environmental impact statement is legally and technically flawed.
At a time when the Gulf oil disaster has people across the United States questioning our continuing reliance on fossil fuels, the Administration has a duty to be very careful in its assessment of new and risky oil projects. The proposed Keystone XL tar sands pipeline would move our country backwards in continuing our dependence on a dirty, risky and expensive source of fossil fuel at a time when we should be choosing cleaner alternatives.
A sound analysis of the Keystone XL tar sands pipeline would show that it was not necessary and that it will cause significant and unpreventable environmental harm. However, the draft environmental impact statement did not provide a sound analysis. The information provided was tired and cursory, relying on inaccurate assumptions made around earlier pipelines. This might have slipped past in prior years, but the awareness of the need for government oversight of new oil projects is acute now in the wake of the Gulf oil disaster. The comments start by outlining some of the most urgent reasons for additional oversight of pipeline safety – just in the first half of 2010 a number of business-as-usual pipeline ruptures in the United States have caused thousands of gallons of oil to spill.
The State Department as the agency responsible for permitting this trans-boundary pipeline should do a proper analysis so that the Administration can evaluate the actual environmental impacts and national interest in expansion of tar sands. They should do this through a new draft environmental impact statement that is open for public comment prior to releasing a final environmental impact statement.
Specifically, our analysis of the draft environmental impact statement includes the following points that need to be corrected before a final environmental impact statement should be issued:
- Inadequate analysis of the risk of spills, especially where the pipeline crosses the Ogallala Aquifer, the main source of freshwater for eight states in America’s heartland.
- Lack of a separate assessment of the environmental impacts if a requested safety waiver is granted to use thinner steel in this high pressure pipe in order to save TransCanada money.
- Lack of analysis of the environmental and health impacts of extraction of tar sands oil in Canada, including greenhouse gas emissions and elevated levels of cancers in downstream Aboriginal communities. This even though the Keystone XL pipeline would clearly be a driver of tar sands oil expansion in Canada.
- Totally inadequate analysis of the pipeline impacts in the United States on waters, wildlife, endangered species, migratory birds, and on native grasslands and sandhill ecosystems.
- Lack of analysis of associated tar sands refining impacts, especially in areas that already face environmental justice pollution issues in the Gulf Coast region. These environmental justice impacts should also have been part of the analysis.
- Lack of an analysis of the actual need for the additional imports of tar sands oil that the pipeline would represent and lack of an assessment of alternatives that includes non-fossil fuel alternatives.