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EPA Schools State Department On Keystone XL Pipeline

The deadline for public comments on the State Department’s environmental review of the Keystone XL tar sands oil pipeline passed on Monday, and the U.S. Environmental Protection Agency came in just under the wire with a scathing review of the review. The failing grade won’t surprise opponents and reporters covering the project, who traced the authorship of the review back to a consulting firm paid by TransCanada, the Canadian company behind Keystone XL.

To be fair, though, EPA’s seven-page comment wasn’t all bad news: in an introductory paragraph, Assistant Administrator Cynthia Giles provides a consoling pat on the back (a sincere one, we presume), writing that “While we appreciate this effort, we also have several recommendations for improving the analysis…”

EPA criticizes State Department's Keystone review

F by Just some dust.

The Keystone XL Pipeline Review, Part 1

To put the EPA’s review in context, earlier this year the State Department issued its official Draft Supplemental Environmental Impact Statement (DSEIS) for the Keystone XL pipeline, which is designed to carry tar sands oil slurry from fields in Canada, down through the Midwestern U.S. to Gulf Coast refineries for ready access to the global export market.

The mildness of the review was met with dismay by pipeline opponents, who are relying on the Obama Administration to refuse approval for the project based on environmental risks including global climate impacts as well as local water and land resource impacts (State Department approval is required for the project, since the pipeline crosses an international border).

Some sleuthing by Brad Johnson (via soon revealed that the review was not prepared by State staff, but was the product of a consulting firm paid by TransCanada. That’s fair enough as far as it goes, since reviews like these are highly technical and few agencies have the resources to conduct them in-house. However, the review basically boiled down to two rather lame arguments, which we’ll detailed below.

The Keystone XL Pipeline And Greenhouse Gas Emissions

The first argument revolves around greenhouse gas emissions, and while State concedes that lifecycle greenhouse gas emissions from tar sands oil is far greater than conventional oil, it basically argues that the pipeline should be approved because if it is not, the emissions will simply make their way into the global market by alternate routes (I know, that’s really lame but whatever).

State admits that additional pipelines for Canada’s tar sands oil are probably not an option, but that still leaves rail as feasible possibility, both logistically and economically.

EPA pounces on this one, noting that “the discussion in the DSEIS regarding energy markets, while informative, is not based on an updated energy-economic modeling effort.”

EPA anticipates that rail transport would cost much higher than the DSEIS accounts for, with the added complication that current and potential railway infrastructure would not be sufficient to enable a smooth flow of rail traffic.

For that matter, communities in the Pacific Northwest are already mobilizing vigorously against proposed new rail terminals for coal exports, so despite the promise of job growth in coastal communities, it is hardly likely that increased rail traffic from tar sands oil would be met with open arms.

Dilbit And Pipeline Safety

The second issue focuses on local risks from pipeline spills and breaks. Keystone XL supporters generally avoid discussing the actual contents of the pipeline’s carriage, which leads to the impression that the impact of spills or breaks would be no more or less severe than with any other of the pipelines that already criss-cross the U.S.

Again, that’s a pretty lame argument (everybody else is doing it, so why can’t we?). However, EPA reveals that it is also disingenuous, to say the least. That’s because, as EPA emphasizes several times within its comment, tar sands oil is not like conventional oil. It consists of heavy bitumen that is diluted into a transportable slurry, typically by mixing it with benzene, naphtha or natural gas condensate.

The difference in impacts and clean-up logistics is significant, as EPA notes by referring to the 2010 Enbridge spill of oil sands crude in Michigan.

In a conventional spill, oil floats to the surface where it can be skimmed off or contained. EPA notes that in contrast, the Enbridge spill dumped heavy crude into the Kalamazoo River, where it sank and mixed with bottom sediment. EPA has determined that it will not biodegrade and that a full dredging operation will be required to clean up the mess.

EPA provides a long, detailed rundown of spill prevention and response measure that would be required to satisfy a minimum of public and environmental safety issues.

However, EPA also notes that even the DSEIS itself recognizes that short term clean-up efforts would not resolve issues related to the dissolved components of dilbit including benzene, polycyclic aromatic hydrocarbons and heavy metals, which could be released over a period of “many years.”

As if to punctuate EPA’s concerns, the more recent Exxon spill in Arkansas last month illustrates how even a relatively small spill of dilbit can create a lasting local disaster.

F Is For Insufficient

The end result of all this is that State earned itself an EO-2, meaning Environmental Objections – Insufficient Information:

“The EPA review has identified significant environmental impacts…Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative).”

So, it looks like it’s back to the drawing board for Keystone, at least for the time being.


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Tina specializes in military and corporate sustainability, advanced technology, emerging materials, biofuels, and water and wastewater issues. Views expressed are her own. Follow her on Twitter @TinaMCasey and Spoutible.


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