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U.S. Environmental Protection Agency's letter about TransCanada's Keystone XL pipeline

U.S. Environmental Protection Agency's letter about TransCanada's Keystone XL pipeline

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Published by The Globe and Mail
The EPA said in a comment letter that the State Department’s draft environmental impact statement contained inadequate information on the effects of the proposed pipeline, and suggested more study, a recommendation that could further delay the long-stalled project.
The EPA said in a comment letter that the State Department’s draft environmental impact statement contained inadequate information on the effects of the proposed pipeline, and suggested more study, a recommendation that could further delay the long-stalled project.

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Published by: The Globe and Mail on Apr 23, 2013
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04/24/2013

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WA
SHIN
GTON.
DC
20460
APR
22
2013
ASSISTANT AOMIMSTRATOR FORENFORCEMENT
AND 
COMPLIANCEASSURANCE 
Mr. Jose
W.
FernandezAssistant SecretaryEconomic, EnergyandBusiness AffairsU.S.Department
of
StateWashington, DC 20520Dr.
Ke~rri-Arm
JonesAssistant SecretaryOceansand InternationalEnvironmentalandScientificAffairs U.S. Department
of
StateWashington,DC 20520DearMr. Fernandezand Dr. Jones:
In
accordance with our authoritiesunderthe National Environmental Policy Act(NEPA) and Section 309
of
the Clean Air Act, EPAhasreviewed the Department
of
State'sdraftSupplemental Environmental Impact Statement(DSEIS) for a Presidential Permitapplication byTransCanada KeystonePipeline, LP(TransCanada)toconstruct and operatetheKeystone
XL
Project(Project). This DSEIS builds
on
the Department
of
State's August 2011FinalEIS, and includes informationregardinganewproposed route inNebraska.NEPA serves animportantrolein thedecision makingprocessforfederalactions thatmay haveenvironmental effects. Through the NEPA process,federalagencies discloseand analyze the potential impacts
of
a proposed action andreasonablealternatives, aswell as measures that could mitigate any potential harmfuleffects.NEPA bringstransparencytothe federal decision makingprocess,requiring thatotherfederal, state, tribal andlocalagencies, as we
ll
as citizens, are given a meaningfulopportunity
to
provide comments, helping to ensure federal decisions arebetterinformed.EPAbelieves thisDSEIS strengthenstheanalysispresentedtodate
in
theNEPAprocess.While we appreciatethiseffort,wealso haveseveral recommendationsfor improving the analysis and considering additionalmitigationasyou move forward to complete the NEP A process.
lntemel Add•ess (URL)hnp://www.epa gov 
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Greenhouse GasEmissionsWecommendthe Department
of
State's effortstoestimate the
lif
ecyclegreenhouse gas (GHG) emissions associated with oil sa
nd
sdevelopmentandthe proposed Project, to analyze the effect
of
the Project on Canadian oilsandsproductionandto,consider measures to reduce
GHG
emissions.Asrecognized
by
the DSEIS, oilsands erudeissignificantlymore
GHG
intensive than other crudes,and thereforehas potentially large climate impacts.
The
DSEIS reports thatlife
cycle
GHG
em
issionsfrom oilsandscrudecould
be
81% greater thanemissionsfrom the averagecruderefmed in the U.S.
in
2005 ona
we
ll-to-tankbasis, and 17%greater
on
awell-to-wheelsbasis.
1
Thisdifference may beeven greaterdependingonthe assumptions
made? The
incrementalemissions from oilsandscrudetransported
by
the Project would therefore
be
18.7millionmetric tons
C0
2
-e(carbondioxideequivalent) per year
when
compared to an equalamounlt
of
U.S. average crudes, based
on
the Project's full capacity
of
830,000 barrels
of
oilsandscrude
per
day.
3
To place this difference in context, we recommend usingmonetizedestimates
of
the social cost
of
the
GHG
emissionsfrom abarrel
of
oil sandscrude comparedto averageU.S.crude.If GHGintensity
of
oilsandscrude is notreduced,over a50 yearperiod the additional
C0
2
-efromoilsands crude transportedby the
pip•e
linecouldbe as much
as
935 million metrictons.
It
isthis difference in GHGintensity-betweenoilsandsand othercrudes-that is a major focus
of
the public debateabout
tlhe
climateimpacts
of
oil sands crude.Althoughthe DSEIS describes the GHG intensity
of
oilsandscrude, the DSEIS neverthelessconcludesthatregardless
of
whether the Project permit isapproved,project•!d oilsandsproduction will remainsubstantiallyunchanged. Thisconclusion
is
based
on
an analysis
of
crudeoil markets and projections
of
oilsands crudedevelopment, includi
ng
th
epotential for other means
of
transport to bring oilsandscrude to market.One
of
the alternative transport possibilitiesdiscussedintheDSEIS is the potential construction
of
otherpipelines.
As
part
of
thisdiscussion, the DSEIS appropriatelyrecognizes that there is uncertainty about when,
if
ever, additional pipelines
will
be built.In light
of
these uncertainties,theDSEISexamines options fortransportingoil sands crude
by
rail,andconcludesthat scalinguptransport by rail
js
logistically andeconomicallyfeasible,and that market forces will result
in
additional rail transport
of
oilsandscrude
if
theProjectis not built.
It
is this findingthatsupports the DSEIS'overall conclusion that approval
of
thepermitwillnot by itselfsubstantially affectGHG emissions
or
contribute
to
climate change.
1
DSETS,
Table
4.15-22
"GHG Emissions for Producing Gasoline from DifferentCrude Sourcesfrom NETL 2009 andEstimates
of
the Impact
of
KeyAssumptions
on
theOil
Sands-
U.S. AverageDifferential." Inadditiontolifecycleemissionsestimates fromtheDepartment
of
Energy's NationalEnergyTechnology Laboratory
(NETL)
study,the DSEISalsoprovidesestimates from otheranalyses.See discussion
in
DSEIS
sec
tion
4.15.
2
DSEIS.p. 4.15-106,"Adjusting the
NEIL
results to include otherproductemissions couldincrease the differential in incremental emissions from WCSBoilsandscomparedto the2005 U.S.average crude oils byroughly30 percent."
3
DSEIS
p.
4.15-105
2
 
Themarketanalysisandthe conclusion thatoilsandscrudewill find a way to market:with
or
without theProjectis the central findingthat supportsthe
DSEIS's
conclusionsregardingthe Project'spotentialGHG emissionsimpacts.Becausethe market analysisis so centralto this keyconclusion,wethinkit is important that it be as completeandaccurate aspossible.Wenote that the discussion inthe DSEISregarding energy markets, whileinformative,isnot based
on
an updated energy-economicmodeling effort. The DSEISincludesa discussion
of
rail logisticsand the potentialgrowth
of
rail asatransport option,however werecommend thatthe FinalEISprovide a more careful review
of
themarket analysis and rail transport options. Thisanalysis shouldincludefurtherinvestigation
of
railcapacity and costs,recognizingthe potential for
mu
,chhigher
per
barrelrail shipment costs than presented
in
the DSEIS.This analysisshould consider
how
thelevel and pace
of
oil sands crude productionmight beaffectedby higher transportationcostsand the potential for congestion impactstoslowrail transport
of
crude.
In
its discussion
of
practicable options for mitigating
GHG
emissions,the DSEISoutlines ongoingeffortsby the government
of
Alberta toreducethe GHG emissions associatedwi
th
development
of
oil sandscrudein Alberta. EPA recommends thatthe Final EIS complement this discussionwith an exploration
of
specific waysthatthe U.S.might work with Canada topromotefurtherefforts toreduce GHG emissions associated with the production
of
oilsandscrude,includinga
joint
focus
on
carbon capture
and
storageprojectsandresearch, as wellas ways toimprove energyefficiency associated withextraction technologies.Withregard to theestimated GHG
em
issionsfromconstructionandoperation
of
theproposed Project-primarily emissions associatedwith electrical generation for thepumpingstations-we recommend that the Department
of
State explore specific commitments that TransCanadamightmaketo implementthe mitigation measures recommended in the DSEIS. Thiswouldcomplementthesignificant effortsalreadymade
to
reduce the
risk
of
spillsand ensure community safety. Specifi,cally,we recommend afocus
on
pumping station energy efficiency anduse
of
renewableenergy, as well asinvestmentin other carbonmitigationoptions. PipelineSafetyWe havelearnedfromthe2010 En bridge spill
of
oil sands crude in Michiganthatspills
of
diluted bitumen (dilbit)
4
mayrequiredifferent response actions
or
equipmentfrom responseactions for conventionaloilspills.These spills can alsohave different impactsthan
sp
ills
of
conventionaloil.We recommendthatthese differencesbe more fully adldressed intheFinal EIS, especia
ll
y asthey relate
to
the fate and transport
of
theoiland the remediationthat willberequired. The Enbridge spillinvolveda 30-inch diameter pipeline,smallerthan the36-inch diameterpipeline for propo
se
dProject,and20,000 barrels
of
oil sands crudewere released.
In
thatspill, oil sands crude sankto thebottom
of
the KalamazooRiver, mixingwith the riverbottom'ssediment and organic matter, makingthe oil difficult tofindand recover. After almost three years
of
recovery
4
As noted
in
tbe DSEIS,transporting oilsa
nd
s crudevia pipeline requires that
it
bemixedwith a petroleum-based product(ca
ll
eda diluent), suchasbenzene,naphtha
or
naturalgas condensate,
to
makealessviscous liquidcalled dilbit (diluted bitumen). 3

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