Action 30. Tell the State Department what I think of their Keystone EIS.

According to the recently released draft Environmental Impact Statement (EIS) for the Keystone XL pipeline, “For proposed petroleum pipelines that cross international borders of the United States, the President, through Executive Order 13337, directs the Secretary of State to decide whether a project is in the national interest. ”

In my opinion, this EIS is it is far from an objective review of the proposal as to whether it is in the national interest; frankly, it reads like the State Department is bending pretty far backwards to kiss somebody’s caboose. Read on and see what you think. What follows is substantive of my comments to the State Department on their review.

“The new proposed route is 509 miles shorter than the previously proposed route; however, it would be approximately 21 miles longer in Nebraska to avoid sensitive areas including the NDEQ-identified Sand Hills Region. Thus, the newly proposed route is substantially different from the previous route analyzed in August 2011 in two significant ways: it avoids the NDEQ-identified Sand Hills Region and it terminates at Steele City, Nebraska.”

Right, they’re avoiding a sensitive wildlife area, that is a good thing (and also a legally required thing, so let’s not pat them on the back too hard for this one); as for the decrease in length, I note that Keystone has parsed off the entire section from Oklahoma to the gulf coast as a separate project, so, they no longer have to include that in their accounting of the pipeline length. How convenient; but it doesn’t mean that that additional mileage isn’t being built, just that it no longer has to be reviewed by the state department as part of the international project!

“If permitted, when in operation, the proposed Project would maintain a 50-foot, permanent easement over the pipeline. Keystone would have access to property within the easement, but property owners would retain the ability to farm and conduct other activities.”

Interesting; this statement doesnt exactly jive with TransCanada’s actions to date, which has included some pretty substantive condemnation of private property by eminent domain.

“Emissions during operation of the proposed Project would be approximately 3.19 million metric tons of CO2e per year, almost entirely due to electrical generation needed to power the proposed Project’s pump stations.”

While this number estimates the yearly emissions associated with the operation of the pipeline, it does not appear to be even close to a thorough accounting of the GHG emissions associated with the extraction, conveyance, and consumption of this oil, which also includes:

  • the destruction of 740,000 acres of boreal forest which are themselves a major natural sink of carbon, in order to access the tar sands;
  • according to OilChange International’s recent report, the petcoke produced from the Keystone Xl pipeline would fuel 5 coal plants and produce 16.6 million metric tons of co2 each year; these petcoke emissions have been excluded from State department emissions estimates for the Keystone Xl pipeline, and including these emissions raises the total annual emissions of the pipeline by 13% above the State department’s calculations. Just because petcoke is a refinery byproduct, that does not mean it should not be part of the accounting as it is part of the lifecycle of the product that will be transported by this proposed pipeline.
  • Lifetime emissions of this project were estimated by EPA to be as high as 600 million to more than a billion metric tons of CO2 in their comments on the last draft EIS. That letter from EPA also recommended the inclusion of “an estimate of the “social cost of carbon” associated with potential increases of GHG emissions, which EPA defines as including, but not limited to, “climate damages due to changes in net agricultural productivity, human health, property damages from flood risk, and ecosystem services due to climate change. Federal agencies use the social cost of carbon to incorporate the social benefits of reducing CO2 emissions into analyses of regulatory actions that have a marginal impact on cumulative global emissions; the social cost of carbon is also used to calculate the negative impacts of regulatory actions that increase CO2emissions.” None of that accounting appears to have been done for this report.

“Approval or denial of any one crude oil transport project, including the proposed Project, remains unlikely to significantly impact the rate of extraction in the oil sands, or the continued demand for heavy crude oil at refineries in the U.S.”

While it is highly unlikely that TransCanada will pack up and go home if Keystone is not permitted (for example, rail as an alternative transport method is clearly already rapidly growing), with a capacity of 830,000 barrels per day, Keystone XL is the largest and most significant proposed oilsands pipeline. According to this report from a Canadian clean energy consulting organization, If Keystone XL was filled, it would support over a 36 per cent increase in oilsands production. Meanwhile, reports from Canada show quite a different picture than the one that has been painted here by the State Department regarding the importance of Keystone to tarsands development, suggesting that lack of pipeline capacity is a limiter on tarsands development, and that Canadian opposition to pipeline development is quite strong and casts the building of pipelines across Canada into doubt.  Given these facts, its incredibly hard to understand how the State Department came to the conclusion that Keystone wont make a difference one way or the other.

“The long-term contracts supporting the proposed Project indicate that refiners see economic advantages to processing heavy WCSB crude oil…”

“Including direct, indirect, and induced effects, the proposed Project would potentially support approximately 42,100 average annual jobs across the United States over a 1- to 2- year construction period (of which, approximately 3,900 would be directly employed in construction activities)… Generally, the largest economic impacts of pipelines occur during construction rather than operations. Once in place, the labor requirements for pipeline operations are relatively minor. Operation of the proposed Project would generate 35 permanent and 15 temporary jobs, primarily for routine inspections, maintenance, and repairs.

So the primary economic benefits this pipeline is bringing, according to the state department, are several thousand extremely short-term jobs (note that the parenthetical number of 3900 is the actual estimate of construction jobs; the rest of that number is made up of folks like the Walmart worker that sells stuff to the construction worker for that couple years that they are making money on the project), the supply of more product to refiners, and a tiny number of permanent jobs (and in a testimony to the misleading information surrounding this project, its incredible to see what a fuss has been kicked up about all the jobs lost if this permit isnt secured, relative to the reality of a few thousand temporary construction jobs and almost no permanent jobs resulting from this project), in return for rather staggering economic and environmental costs to the many sectors and ecosystems affected by this proposal. Personally, I’m not seeing the math adding up in favor of our national interests. And at least some of our labor organizing groups seem to agree with this conclusion.

So, suffice it to say, I am seriously underwhelmed- and concerned- by the quality and thoroughness of this report, and I’ll be letting the State Department hear my concerns. You can too: keystonecomments@state.gov.

UDPATE:  Critical Part of Keystone Report Done by Firms with Ties to Oil Industry. So, so unsurprising. I will be quick to say that most consulting firms work on multiple sides of a given industry issue; the firm I used to work for had a huge range of clients from private in oil and gas to public agency and nonprofits. Just because consultants work for oil and gas, that does not necessarily preclude ones ability to provide credible, independent work for a different client. However, I do believe that the fact that the majority of the preparers come from a company who currently does work for companies actively involved in tar sands mining should give the reader pause; and I would say the tenor of this report does little to assure us that their work is objective.

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