EPA Slams State’s Draft Impact Statement For Keystone XL

On the proposed Keystone XL pipeline, EPA rated the adequacy of the State Department’s Draft Environmental Impact Statement (DEIS) as having “Insufficient Information.”

In case you missed it, today is the last day to submit public comments to the State Department regarding the proposed pipeline that would transport 830,000 barrels of tar sands oil through the U.S. per day.

EPA’s Cynthia Giles, the Assistant Administrator for the Office of Enforcement, has submitted the agency’s public comment. They could have rated the adequacy of the impact statement three different ways: “Adequate,” “Insufficient Information,” or “Inadequate.” They rated it “Insufficient Information,” which means that they do not know enough to fully assess the environmental impacts of a tar sands pipeline traversing the continent.

Here are the reasons EPA said that State’s DEIS needs more work:

  • Increased carbon pollution: EPA acknowledged the DEIS’s attempt to do a life-cycle analysis of the pipeline’s emissions, which found that emissions from oil sands crude would be 81 percent higher than regular crude, or an incremental increase of 18.7 million metric tons of CO2 per year. EPA noted that “If GHG intensity of oil sands crude is not reduced, over a 50 year period the additional CO2 from oil sands crude transported by the pipeline could be as much as 935 million metric tons.” These statistics are alarming, yet EPA’s analysis did not stop there.
  • Not inevitable: Like other experts, EPA doubted State’s assurance that this tar sands oil would come out of the ground with the Keystone pipeline or without it:

    The market analysis and the conclusion that oil sands crude will find a way to market: With or without the Project is the central finding that supports the DSEIS’s conclusions regarding the Project’s potential GHG emissions impacts. Because the market analysis is so central to this key conclusion, we think it is important that it be as complete and accurate as possible.

    It then goes on to detail the ways in which this market analysis is incomplete: It uses outdated modeling, and the expense and infeasibility of rail shipping as an alternative to Keystone both need to be considered.

  • Pipelines don’t pump themselves: EPA recommends that renewable energy be used to power the pumping stations along the pipeline, because otherwise the constructed pipeline itself will actively emit GhG emissions.
  • Tar sands oil is particularly dirty to clean up: The EPA notes that diluted bitumen is very dense and sinks to the bottom of rivers and lakes. The 2010 Enbridge spill will require dredging, because normal cleanup methods do not suffice. The Keystone pipeline would be 36 inches in diameter — larger than the pipe that leaked 20,000 barrels of oil in the Enbridge spill. EPA notes that dilbit contains some very toxic materials “such as benzene, polycyclic aromatic hydrocarbons (PAHs), and heavy metals” that “could cause long-term chronic toxicological impacts” to wildlife. EPA recommends including a seriously revamped and rethought response plan as conditions before any permit is issued to build a pipeline.
  • Who needs drinking water?: Though Keystone’e proponents received praise for moving the original route away from the Sand Hills, it still crosses the Ogallala Aquifer. The EPA notes there is another way: “The alternative laid out in the DSEIS that would avoid the Ogallala Aquifer is the I-90 Corridor Alternative, which largely follows the path of existing pipelines.” There were additional alternatives that State’s EIS did not address, and EPA asked it to do so.

That does not sound like the a “no-brainer” that Keystone’s advocates have described. That sounds exactly like the nation’s top environmental cops on the beat responding to an assessment of a project made by a firm being paid by the pipeline’s owner.

17 Responses to EPA Slams State’s Draft Impact Statement For Keystone XL

  1. If tar sands development would proceed at the same rate regardless of Keystone XL, tar sands developers wouldn’t be lobbying for it so hard. It’s not as if there are multiple equal pipeline proposals to handle the desired level of development, only one of which will win.

    Not approving Keystone will definitely delay tar sands development. Even a five year delay means more time to debate the wisdom of mining this resource, and more time for climate disruption to show its hand. That’s five years to influence the way people perceive the tar sands venture.

    In five years, we may see some very dramatic and unfortunate changes in the biosphere that could turn the debate. I’m thinking of course of an ice-free Arctic one summer soon, and the consequent erratic weather as the jet stream seeks (and does not find) its new equilibrium.

  2. Bill Wilson says:

    Which standards are used to design and carry this toxic brew under high heat and high pressure with changing temperatures? HOW ARE THE HOLES FROM FAULTY WELDS FIXED ONCE PIPE IS BURRIED? How do the cancers 10 times the normal downstream and growing affect the decision? How do the increaed asthma and heart disease affect the decision? How does the loss of land, water and air quality affect the decision? How does the loss of jobs as we fall further behind China and India for alternatives affect the decision? Many more questions and seems the more these are ignored the more people are starting to realize it is not in the best interest of America, the world or a planet that can survive the increased dependence with no restraint and a President that could say No to the industry of death and destruction for a few dollars more today.

  3. Leif says:

    Dilbit is not even classified as “oil” because it is not oil. It is in fact a close cousin to creosote. Coal tar and thinners. Creosote! Clean up is on the public dime thanks to fossil funded lobbyist and bought off congress-folks. Stop profits from the pollution of the commons.

  4. lizardo says:

    What can I say other than a big woohoo. State and Obama are going to pay more attention to EPA than to say, me, but I got my comments in a few minutes ago (ran out of time to edit into better shape from disparate drafts because I got bogged down in the weeds of all that lifecycle analysis stuff).

    I did include some snarks about some of their market assumptions though which were very self-contradictory I thought. I’m sure EPA did a better job.

    EPA either used all they time they had to get their comments in or were very smart and didn’t want to give TransCanada time for a detailed rebuttal (good luck with that anyhow).

  5. DallasNE says:

    Following is the body of my email yesterday to the State Department. Nothing special but I thought I would share it nonetheless.

    While I have serious environmental concerns with this project I have even more concerns with the proposed route this pipeline will take. And what happened in Arkansas recently just adds to that concern.

    To save money TransCanada has developed the shortest route that can be built. That means that there are a number of places where that route is close to large streams and rivers that cannot simply have earthen dams built to capture the spilled oil. Because of this I think it would make far better sense to follow ridge lines where spillage would flow into mostly dry streams that could easily have a temporary earthen dam built to capture the spilled oil. What this would mean is that the route would stay north of the Missouri River in North Dakota where it would then veer south along the ridge line between the Missouri and Red Rivers then veer back east along the ridge line between the headwaters of the Red and Little Sioux Rivers and again swing south in Iowa along the ridge line between streams flowing into the Mississippi and Missouri Rivers. Yes, that means that it could not connect up at Steele City, NE but so what. It boils down to what are the goals — the cheapest route for TransCanada or the safety of the American people. That decision looks rather easy.

  6. fj says:

    This is sufficient to stop the pipeline.

    Now lets get moving on climate change at wartime speed.

    Poor people first.

  7. fj says:

    5000 people in the first day signed up for New York City bikeshare.

    People in public housing only pay $60 per year.

  8. Mulga Mumblebrain says:

    We’ve had ‘Environmental Impact Statements’ in Oz for decades. As far as I’m aware, no ‘study’ has ever rejected a project as too environmentally damaging to go ahead. And, yet, mysteriously, the environment continues to decay, at an accelerating rate. Passing strange.

  9. fj says:

    Standard rate for bikeshare is only $95 per year.

  10. fj says:

    Bikeshare is very early stage net zero transit.

  11. fj says:

    The bikes in bikeshare are three times more efficient than walking and use the same energy source.

  12. BillD says:

    I also believe that a delay in the pipeline, especially for few years, is a big win. It won’t be long before we are seriously considering a carbon tax, which would seem to put an end to using this source of material for refineries. If we could delay for five years, maybe even the Canadian government and pipeline company will be thanking the US for avoiding the expense. If the pipeline is approved, there should be means for providing very high penalties for any spills.

  13. gtb says:

    For people who want to spread the word about the tar sands, here is some brief, useful additional info from The Climate Reality Project:

  14. mulp says:

    Just one question, or two…

    Will blocking the XL Pipeline result in a strong Democratic majority (65-70 Democrats in the Senate, 275+ Democrats in the House) so a carbon tax is passed by Congress in 2015?

    If not, is there any hope for the future?

  15. Artful Dodger says:

    Keystone XL is, among other things, a huge tax-dodge for major oil companies. By refining the oil in ‘free-trade zone’ refineries on the Gulf Coast, they avoid paying all Federal Income tax on those products.

    If they bring in back into the U.S. then they’d have to pay taxes. Why would they do that when they can put that same oil on a supertanker and send it to Asia and Europe to be sold at the highest World price that exists.

    That’s why they want Keystone XL, specifically. And that’s the most compelling reason why the President should reject this project.

  16. Global Green Hu says:

    It takes more energy to extract and refine tar sands oil, leading to a higher carbon footprint than regular oil.

  17. fj says:

    There’s hope for the future.