Comment Sent to the State Department on the Keystone XL Pipeline

Summary.  TransCanada Keystone Pipeline, L.P has applied for approval to construct a pipeline from Canada to a pipeline terminal in Oklahoma in order to ship “tar sands” oil to refineries on the U. S. Gulf Coast.  The State Department has evaluated the application in its Environmental Impact Statement.  The U. S. must weigh this application to determine whether it meets the national interest.  This post presents a Comment submitted by this writer recommending that the application not be approved, for several reasons.

I. Introduction: The Department of State (DOS) is evaluating the Presidential Permit Application of TransCanada Keystone Pipeline, L.P. (the Application) to determine whether the project serves the national interest.  DOS weighs “a wide range of factors, including … environmental… and economic impacts; [and] foreign policy”, among others.  In this regard DOS issued its Final Supplemental Environmental Impact Statement (Final SEIS) concerning the Application In January 2014.  An earlier application, which was not approved, covered the pipeline’s full length from Canada to U. S. Gulf Coast.  The present Application covers only the northern portion of this route, since construction has already begun on the remainder, which, as a fully domestic project, does not require presidential approval. 

The currently pending project is intended to transport “heavy crude” oil, also called “tar sands” oil, from the Western Canada Sedimentary Basin (WCSB) to the terminal in Oklahoma where the domestic pipeline to the Gulf Coast refineries begins.  The capacity is to be 830,000 barrels of oil per day (bpd); the project portion to Oklahoma is estimated to cost $3 billion. 

DOS is accepting comments on the Final SEIS until March 7, 2014 (Federal Register / Vol. 79, No. 24 /p. 6984).  This post presents a Comment submitted by this writer addressing certain aspects of the Final SEIS, based on the Executive Summary (ES) thereof, and considers broader policy factors affecting the national interest. 

II. Effects of Man-Made Greenhouse Gas Emissions on Global Warming

The Intergovernmental Panel on Climate Change (IPCC) issued the first of three sections of its Fifth Assessment Report (5AR; see the Summary for Policymakers) in September 2013.  It finds that the historical warming of the earth’s climate to date is “unequivocal”.  Since the 1950’s many climate parameters have changed to an extent that is “unprecedented” over decades to thousands of years.  Humanity’s activities, burning fossil fuels to provide energy, have been the dominant factor producing global warming due to the increased emission of the greenhouse gas (GHG) carbon dioxide (CO₂).  5AR projects future climate patterns, concluding that if humanity continues emitting GHGs the earth will warm further, with long-lasting effects.

5AR concludes “Cumulative emissions of CO₂ largely determine global mean surface warming by the late 21st century and beyond…. Most aspects of climate change will persist for many centuries even if emissions of CO₂ are stopped. This represents a substantial multi-century climate change commitment created by past, present and future emissions of CO₂.”  It further states “[Most] anthropogenic climate change … is irreversible on a multi-century to millennial time scale” because there is no natural process operating within this time scale that removes CO₂from the atmosphere. 

The warmer climate will worsen extremes of weather and climate that are already occurring, causing serious harm to people and major damage to the land. 

For these reasons domestic and foreign environmental policy should be guided by the need to abate the continued accumulation of GHGs in the atmosphere.

III. The Final SEIS minimizes impacts of the pipeline project.

A. Lifecycle analysis of GHG emissions omits consideration of the no-transport case.

The Final SEIS presents an analysis of the full lifecycle effect on GHG emissions from operation of the pipeline (Section ES.4.1.2).  It estimates that transporting 830,000 bpd would cause emitting between 147 and 168 million metric tons of CO₂-equivalents (MMTCO₂e) per year. 

The Final SEIS mentions the case in which production from WCSB is reduced by 830,000 bpd, i.e., one in which tar sands oil destined for the proposed pipeline is never extracted.  It argues that no such case need be considered because “…approval or denial of any one crude oil transport project, including the proposed Project, is unlikely to significantly impact the rate of extraction in the oil sands or the continued demand for heavy crude oil”.  This means that the GHG emissions identified above would continue unabated.

It is possible, however, that if the Application is not approved the volume of WCSB oil corresponding to the pipeline’s intended capacity would not be extracted, and that no corresponding emissions would arise.

In other words, the Final SEIS seeks to render futile the possibility that the Application will not be approved by proposing that extraction and shipment not under the control of the U. S.administration would occur regardless.  This is highly improper, for it seeks to make the U. S. complicit in promoting further emissions even if the Application is not approved.  No such responsibility in fact exists.  The U. S., acting in accord with considerations of global environmental policy and its own national interest may indeed decide against approving the Application.  Any consequences of such a decision due to actions of third parties would be beyond the scope and power of the U. S. and should not influence the decision to be made.

B. Assessment of alternative routes for oil transport belittles the no-transport case.

The Final SEIS sets out three alternatives to the pipeline project (Section ES.5.0 and subsections therein); a) the No Action Alternative, presenting potential market reactions if the pipeline is not constructed; b) Major Route Alternatives for transporting oil to Steele City, NE (just upstream from the Cushing, OK terminal); and c) Other Alternatives presenting additional route options and alternative pipeline designs.

The No Action Alternative includes an assessment of a Status Quo Baseline, according to which no pipeline would be built and no emissions would arise.  This reflects the current situation.  The No Action Alternative also considers three alternative scenarios involving rail transport of WCSB oil.  All the rail scenarios include loading fourteen 100-tanker car trains per day to transport oil.

Certain Major Route Alternatives are assessed in detail; these would have comparable lengths, costs and environmental impacts as the intended route.

DOS considered Other Alternatives further adjusting routing and design, and concluded that none were appropriate for the purpose of the Application.

Here too, as in Section III.A of this Comment, assessment of the Status Quo Baseline is given scant attention in the ES.  By thoroughly analyzing the rail scenarios and the alternatives, all involving extracting and shipping WCSB oil, the Final SEIS emphasizes the preconception that WCSB oil will indeed reach the Gulf Coast refineries, regardless of whether the Application will be approved or not.

As noted in Section III.A, here too the Final SEIS infers the futility of not approving the Application by strongly implying that importation will occur in any case, in ways no longer under the control of the U. S. administration.  This is highly inappropriate, for it seeks to burden the U. S. government with consequences of promoting further GHG emissions even if the Application is not approved.  No such attribution in fact exists.  The U. S., acting in accord with its global environmental policy and its own national interest may indeed decide against approving the Application.  Any consequences of such a decision due to actions of third parties would be beyond the scope and power of the U. S. and should not influence the decision to be made.

IV. U. S. Climate Change Policy

A. Greenhouse Gas Emissions

The lifecycle analysis presented in the Final SEIS estimates that, if operational, the pipeline would emit between 147 and 168 MMTCO₂e per year, throughout its lifetime.  Oil pipelines have lifetimes of 30 years or longer. The permit for the Alyeska pipeline, for example, has been extended so that it may remain operational for 57 years.  Thus approving the present Application would single-handedly significantly increase the world’s atmospheric CO₂ burden.  An emission level of 158 MMTCO₂per year, for example, would correspond to about 2.7% of present U. S. annual emissions produced by burning fossil fuels (fossil fuel data).  Because of the harms brought by increasing GHG concentrations, the U. S. should be embarking on policies that avoid adding new GHGs to the atmosphere.  Approving the Application would have the opposite effect, worsening global warming.

B. President Obama’s stated policy is to reduce GHG emissions.  His Second Inaugural Address in January 2013 stated “We will respond to the threat of climate change, knowing that the failure to do so would betray our children and future generations.”  The President’s Climate Action Plan issued June 2013 reiterates his “pledge that by 2020, America would reduce its greenhouse gas emissions in the range of 17 percent below 2005 levels if all other major economies agreed to limit their emissions as well.”  The Plan stated “…we have a moral obligation to future generations to leave them a planet that is not polluted and damaged”, recognizing that extreme weather and climate events in the preceding year, attributed at least partly to global warming, cost the U. S. over $110 billion.

Approval of the Keystone XL Application would enshrine significant new GHG emissions for up to half a century or longer.  This would directly contravene the President’s pledge to honor our “moral obligation to future generations” to mitigate global warming.  It would make it harder to attain meaningful reductions in the future.

C. The U. S. is involved in negotiations for a worldwide pact to reduce GHG emissions.  Long-term negotiations sponsored under the United Nations Framework Convention on Climate Change are in progress, with the intention of reaching agreement by 2015 and entering into force in 2020.  If successful it presumably would cover ratifying members of the U. N.  Secretary of State John Kerry and his Special Envoy for Climate Change are directly involved in these negotiations.  Approval of the Application would critically jeopardize these negotiations, and would make it harder for the U. S. to attain international agreement to limit GHG emissions.

D. Climate models show that the longer we wait to undertake abatement of emissions, the more intensive and the more expensive those efforts will be.

Calls to action have been made at least since the first IPCC Assessment Report in 1990, and have become more urgent as the global climate situation worsens.  Recent urgings include those from Thomas Stocker, a Coordinating Lead Author of 5AR, and James Hansen, formerly head of NASA’s Goddard Institute for Space Studies.  In 2013 Stocker wrote “…every year counts; if mitigation actions are delayed, much larger emissions reductions are later required to maintain a selected [emissions reduction] target”.  Also in 2013 Hansen and many coworkers including Jeffrey Sachs of the Earth Institute at Columbia University wrote “…the world must move rapidly to carbon-free energies and energy efficiency, leaving most remaining fossil fuels in the ground, if climate is to be kept close to the Holocene [the present geological epoch] range and climate disasters averted”.   There is overwhelming consensus among climate scientists that humanity has to migrate from fossil fuels to renewable energy sources as early as practicable.  The U.S. would promote these goals by denying the present Application.

E. The anticipated cost of the Keystone XL pipeline, if redirected, could be used to install significant renewable energy capability.  The Final SEIS estimates the cost for the U. S. portion of the pipeline project (from the Canadian border to an existing pipeline in Nebraska) at $3 billion.  Cost overruns in such projects are not unusual, and could double the cost.  One alternative to invest such a sum would be construction of wind turbine farms and transmission lines from the farms to urban areas for distribution.  Using information from the Lawrence BerkeleyNational Laboratory and the American Electric Power Company, it is estimated that dividing a realistic estimate of $4.5 billion evenly between a wind farm and a transmission line could provide 639 2 MW turbines and 703 miles of a 765 kV transmission line.  It would be in our national interest to develop policies and practices that induce fossil fuel energy companies to invest in renewable energy sources.

F. The Final SEIS pays short shrift to the viable option of not approving the application and investing instead in renewable energy.  As noted above, the document improperly seeks to make the U. S. government responsible for added emissions arising from alternative strategies if they are implemented by other, foreign, parties.  It is inappropriate to make such an unfounded attribution.

V. Conclusion

This Comment has identified fundamental omissions in the DOS Final SEIS whose effect is inappropriately to suggest that failure to approve the Application would implicitly implicate the U. S. in the consequences of continued burning of WCSB oil.  DOS and President Obama should resist such implications, and decide the fate of the Application purely according to the national interests of our country.

Those interests lie exclusively in undertaking actions with regard to global warming that safeguard our nation and our planet from further climatic degradation.  This Comment summarizes many facets in the science underlying global warming and policies that we need to undertake to address this critical problem.  In general, as urged by climate scientists around the world, we should not continue policies that expand use of fossil fuels.  Rather, we should develop new practices that promote energy efficiency and use of renewable energy sources.

In this way President Obama can contribute to fulfilling our “moral obligation to future generations to leave them a planet that is not polluted and damaged”.

© 2014 Henry Auer