Comment to the State Department opposing Keystone XL

I have just (finally) submitted my comment to the State Department, urging it to reject the proposed Keystone XL pipeline. I encourage anyone reading this post to submit your own comment to the State Department by 5:00pm today. You can find more information and talking points from 350.org, which is pushing for 1,000,000 public comments. You can email comments to keystonecomments@state.gov.

Join the effort to submit 1,000,000 comments against Keystone XL (courtesy of 350.org).

Join the effort to submit 1,000,000 comments against Keystone XL (courtesy of 350.org).

Here is the text of my comment; feel free to borrow from it liberally:

State Department Office of Environmental Quality and Transboundary Issues:

I would like to make it clear that I firmly oppose the proposed Keystone XL pipeline project and am certain that it does not fulfill a national interest. Moreover, the State Department’s own Supplemental Environmental Impact Statement (SEIS) undermines the case which you have made in favor of the pipeline. I would like to highlight just a few of the problematic claims which your office has made during this review process.

First, the SEIS claims that, in the absence of a the Keystone XL pipeline, tar sands companies operating in Alberta will merely deliver the oil which they extract to or through the United States via other means, principally rail. However, the evidence clearly indicates that this alternative is neither economically nor logistically feasible. The SEIS assumes that it costs $15.50 per barrel to deliver tar sands oil to the Gulf of Mexico for refining; yet, the current price for delivering this double that estimate – $31 per barrel. This fact alone obviates your cost-benefit analysis. Additionally, the current rail infrastructure cannot support the expansion of Alberta’s tar sands industry that Keystone XL would facilitate. Less than 4% of Canadian oil entered the US on rail in 2011. I fail to understand how you project that the existing rail infrastructure – or that which may exist in the near future – can possibly pick up the slack to carry the remaining 96.7% of Canadian crude oil that needs refining.

Secondly, your study grievously downplays the threat that Keystone XL spills pose to the inland waterways. As recent spills in Minnesota (by rail, mind you), Arkansas, and Kalamazoo have demonstrated, tar sands present a clear and present danger to air and water quality throughout America. Two years after the largest inland oil spill in American history, the Kalamazoo River has not fully recovered. ExxonMobil has failed to adequately address the crisis its pipeline crated in Mayflower, Arkansas, and it has effectively taken control of this suburban town for its own devices. We already know that TransCanada’s original Keystone pipeline has leaked at least 20 times since it began operating in 2011. Any one of these spills would become vastly more severe if it occurred from the proposed XL pipeline. Tar sands oil does not float, like normal crude. Instead, it sinks and becomes mixed with sediment, making it nearly impossible to clean up properly in the case of a spill. Furthermore, every time water or wind disrupts that sunken bitumen, it can release into the water, creating ever newer ecological disasters. The EPA recently noted that more than 50% of America’s waterways are in poor shape for human use. Keystone XL threatens to exacerbate this challenge further.

Thirdly, the SEIS makes the odd claim that Keystone XL is of little consequence for climate change. Yet, a comprehensive report released last week shows that the pipeline would carry 181 million metric tons of carbon dioxide equivalent, roughly equal to the carbon potential 51 coal-fired power plants. Imagine making the argument that building 51 new coal-fired power plants would be in the national interest. This statement is absurd on its face. In 2007, the Supreme Court ruled in Massachusetts v. US EPA that if the government determines carbon dioxide constitutes a hazardous material, it is obligated to regulate it under the Clean Air Act. I fail to see how building 51 new coal plants or approving a pipeline that meets the same end fits within the confines of this endangerment ruling.

Fourthly, the SEIS claims Keystone XL is in the national interest, as it reduces dependence on oil from Middle Eastern sources. Yet, the very market analysis included in your report suggests that most of the tar sands oil that would travel through the pipeline is destined for export to other countries, particularly the emerging economies of East Asia. How exactly does facilitating the export of oil from Canada to China, in order to benefit a handful of tar sands companies, benefit the American people?

Lastly, your SEIS began from the assumption that Keystone XL would secure approval, then justified its way to this predetermined outcome. This approach violates the spirit, if not the letter, of the National Environmental Protection Act. Your job, as a reviewing agency, is to weigh the benefits and costs of the proposed project and determine whether or not it is in the national interest. This review process failed to meet that essential criterion, undermining any findings which it may have produced. In addition, the State Department apparently tried to hide the fact that the consultants who completed the SEIS have business dealings with TransCanada and may have a financial interest in seeing this pipeline come to fruition, as a result.

Ultimately, the State Department’s own analysis belies the conclusion that Keystone XL stands in the national interest. If the US is committed to fighting the existential threat posed by climate change, as President Obama has eloquently stated, it must stop making decades-long investments in large-scale fossil fuel infrastructure projects. Now is the time to act on climate change, and rejecting the Keystone XL pipeline is a first step toward this end. I urge the State Department to reconsider its stance and recommend that President Obama reject the project. Twenty years from now, we will all be accountable for the consequences of our actions. It is time for the US government to stand on the right side of history and commit itself to tackling the climate crisis.

Sincerely,

Tim Kovach

MA Candidate, Global Environmental Policy

American University School of International Service

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