Keystone Pipeline: Environmental Impact Statement Revisited
Map shows the segment of the proposed Keystone XL Pipeline assessed in a new environmental analysis conducted for the State Department. (Map used with permission. Credit: National Geographic and International Mapping)
The latest event: the pipeline rupture in Arkansas. On Friday, an Exxon Mobil pipeline running from Illinois to Texas ruptured and spilled an undetermined amount of heavy crude from western Canada near the town of Mayflower, Arkansas.
The Environmental Protection Agency has reportedly classified the event as a “major spill” — a definition [pdf] that indicates a spill greater than 10,000 gallons or one that regardless of size “poses a substantial threat to public health or welfare of the United States or the environment or results in significant public concern.”
Exxon Mobil officials say they are preparing for a spill of as big as 420,000 gallons; as of Tuesday, EPA had reportedly estimated it to be around 84,000 gallons. (See Exxon Mobil press release [pdf] and the National Response Center’s incident report.)
The Enbridge Kalamazoo Spill … Still Going
The last time we experienced a pipeline rupture of this magnitude was in the summer of 2010, when an estimated 819,000 gallons of oil spilled from an Enbridge pipeline into Michigan’s Kalamazoo River. As of last month, submerged oil remained in the river, and on March 14, 2013, EPA ordered the company “to do additional dredging in Michigan’s Kalamazoo River to clean up oil from the … July 2010 … spill” to “prevent [it] from migrating to downstream areas where it will be more difficult or impossible to recover.” (See Enbridge’s response to the order.)
Okay, some might say, these spills are unfortunate but given the tens of thousands of miles of crude oil pipelines crisscrossing the United States, two spills in almost three years is pretty good. Some might say that, but they’d be misinformed. In fact between January 2002 and June 2012, the Pipeline and Hazardous Materials Safety Administration database reveals that there were almost 1,700 crude oil pipeline incidents in the United States. (See ProPublica’s interactive map of pipeline incidents.) About 4 percent of these were categorized as “large spills,” meaning between 42,000 and 840,000 gallons [pdf] were released. That translates into a large spill about every two months and that’s not good.
In the meantime, TransCanada folks are assuring us that their proposed Keystone XL pipeline is safe. And proponents are pointing to the State Department’s recent draft supplemental environmental impact statement to validate their arguments — see here, here and here. This statement in particular is being quoted to bolster support for the project:
“The analyses of potential impacts associated with construction and normal operation of the proposed [Keystone Pipeline] Project suggest that there would be no significant impacts to most resources along the proposed Project route.”
Now, the statement is not exactly prominently featured in the report (more on this later) — it appears in Volume II, Section 4.16 under the heading “Summary of Impacts” [pdf]. But you gotta admit, it’s pretty definitive. Reading between the lines, I get something like this: all you people opposing the pipeline on environmental grounds should tear up your protest signs and go home.
“No Significant Impacts” — Really?
Well, even though I haven’t carried around a protest sign in a long time, I am bothered. We’re talking about an 875-mile pipeline segment with the capacity to carry about 830,000 barrels of crude oil per day. Could such a facility really not pose a significant environmental impact? Seems like a stretch to me. Maybe the devil’s in the detail of “most” — “there would be no significant impacts to most resources.” Or maybe it’s something else.
I decided to dig deeper into the report, and you know what? The bulk of its analysis doesn’t seem to support the “no significant impact” statement from Section 4.16. Here are some reasons why.
Analysis Not Complete
Turns out that some potential environmental impacts have yet to be fully analyzed. For example, assessments of the impacts of the pipeline and possible accidents on so-called high consequence areas from both a drinking-water and ecological perspective are “pending and will be included in the Final Supplemental EIS.” (Source)
How can you conclude there will be no significant impacts when you have yet to complete the analyses for high consequence areas? I don’t think you can.
Significant Consequences Listed in Report
The report lists some pretty serious environmental consequences of the pipeline operation — consequences that are not singled out to be likely but are also not characterized as highly unlikely. These include having to provide a “supplemental drinking water supply” to residents because of contamination, the “complete loss of habitat” and/or “permanent loss of land use.” (Source [pdf])
If I lived near the projected pathway of the pipeline, I’d find those impacts to be quite significant.
There Will Be Accidents
Okay, you may say, the consequences could be serious but they will only happen if there is an accident, a spill. How do you know that will happen?
Obviously nobody knows for sure what will actually happen, but if history is any indication, I’d say it’s pretty certain that there will be accidents. According to the State Department report, the historical incident rate per pipeline mile per year is 0.003 (see Table 4.13-1 [pdf]). This means that a 300-mile pipeline will have on average about one incident per year. The expanded Keystone pipeline would traverse about 875 miles, so, on average, we could expect almost three incidents each year of the pipeline’s operation.
But not all incidents are that serious. What about large oil spills (defined in the report as those involving 42,000 gallons to 840,000 gallons of oil)? Can we expect any of those? It turns out that only about 4 percent of pipeline incidents are categorized as “large,” so those spills would be much less frequent. But less frequent is not never. For the Keystone Pipeline we could expect on average a large spill every 10 years or so. Bottom line: over the lifetime of the pipeline, there will be many accidents and probably at least one large spill.
Now, the State Department points out that TransCanada promises to take extra measures to mitigate the impact of any spill, but the history of both governmental and industry oversight of pipelines is not terribly encouraging.
So those are some of the reasons I question the “no significant impacts” statement in the environmental impact report, but I gotta take this a little further because I find the statement itself and its appearance hidden away in Section 4.16 to be suspect.
Why Is the “No Significant Impacts” Statement Buried?
Think about it. A conclusion that the pipeline will have no significant environmental impacts is huge. So huge that you’d think the authors would want to feature it prominently in the report, like in the executive summary, the only part of the document that many high-level policymakers and lawmakers will read. Right?
Strangely enough, nothing close to the “no significant impacts” statement appears there. Why not?
And then there’s the State Department’s press briefing on the analysis. This exchange from the transcript of the teleconference between reporters and Kerri Ann-Jones, assistant secretary of the Bureau of Oceans and International Environmental and Scientific Affairs, struck me as especially interesting (emphasis added):
QUESTION [from Jo Biddle of Agence France-Presse]: … We literally have only just opened this report up and it’s very dense and very comprehensive. But could you tell us, overall, if you found the environmental impact of the pipeline would be significant or would it meet the standards that you need for an eventual approval to go ahead?
ASSISTANT SECRETARY JONES: Well, as I said in my opening remarks, again, this is a draft. And so while there is a section where there is a summary discussion, I don’t think it’s – I think it’s somewhat premature to get into that, because we feel that we need to have a public debate. We covered a range of issues regarding what could be environmental impacts, covering what’s been already mentioned on this call – greenhouse gases and climate considerations – as well as groundwater, as well as the ability when you’re passing through somewhat fragile areas, the effects on threatened and endangered species.
So I would just refer you to the summary piece and just say I think it’s premature at this point to really try to come down with strong conclusions, as we want to make sure we get a lot of comments on this and we have a full public debate about the document.
If the report’s conclusion was that there are no significant impacts, why didn’t Jones answer by saying just that? Could it be that is not actually a conclusion of the draft?
Here’s what I think. The report’s seemingly lone (and in my opinion bizarre) statement about “no significant impacts” notwithstanding, of course there are potential environmental consequences of an oil pipeline of the scope of the proposed Keystone XL. To suggest otherwise is to strain credulity. Does that mean we should not go ahead with the project? Not necessarily.
As a democratic society, we should have a discussion about the potential consequences and benefits — and risks — of the pipeline and then decide what to do. (The quasi-public comment period, now open until April 22, is part of that discussion, as is the public hearing on the environmental analysis in Grand Island, Nebraska, slated for April 18.) Any attempt, intentional or not, to short-circuit this discussion by portraying the pipeline as being environmentally benign, is counterproductive and should be treated as such.