The People of America's Oil and Natural Gas Indusry

Dear EPA: Keystone XL Has Been Studied and Studied and Studied

Mark Green

Mark Green
Posted April 23, 2013

The EPA was out yesterday with a letter urging yet even more delay for the Keystone XL pipeline – a project that already has been thoroughly reviewed by the State Department over more than four and a half years. In that context, EPA’s simply trying to heap delay on top of delay. Let's have a look at the first of EPA’s objections to State’s latest review:

The DSEIS reports that lifecycle GHG emissions from oil sands crude could be 81% greater than emissions from the average crude refined in the U.S. in 2005 on a well-to-tank basis, and 17% greater on a well-to-wheels basis.This difference may be even greater depending on the assumptions made.

Sounds ominous, but it’s also true that the difference could be even less, depending on the assumptions. Take the government of Alberta’s assessment:

There’s a 4.9 percent difference between the average oil sands emissions (well to wheels) and those of the average U.S. imported crude oil. Back to EPA:

The incremental emissions from oil sands crude transported by the Project would therefore be 18.7 million metric tons C02-e (carbon dioxide equivalent) per year when compared to an equal amount of U.S. average crudes, based on the Project's full capacity of 830,000 barrels of oil sands crude per day.

But the pipeline won’t be carrying 830,000 barrels a day of oil sands crude. The State report notes that 100,000 barrels of the 830,000 bpd will be crude from the U.S. Bakken region, not Canada’s oil sands. Other estimates indicate about 25 percent of the crude delivered daily by the Keystone XL will be from the Bakken. At the risk of sounding cynical, it looks like EPA is less concerned with the makeup of the Keystone XL’s daily payload and more concerned with getting the highest possible number for calculating climate impact. EPA’s letter:

To place this difference in context, we recommend using monetized estimates of the social cost of the GHG emissions from a barrel of oil sands crude compared to average U.S. crude. If GHG intensity of oil sands crude is not reduced, over a 50 year period the additional C02-e from oil sands crude transported by the pipeline could be as much as 935 million metric tons. It is this difference in GHG intensity - between oil sands and other crudes - that is a major focus of the public debate about the climate impacts of oil sands crude.

Again, it looks like EPA is going for headlines by leaving reason aside. EPA says, “If GHG intensity of oil sands crude is not reduced ...” Is it realistic (or fair) to assume that there will be no technological advances in reducing GHG emissions from oil sands production over the next five decades? No. Back to the government of Alberta:

The oil sands industry has reduced GHG emissions per barrel of oil produced by an average of 26 per cent since 1990, with some facilities achieving reductions as high as 50 per cent.

And back to the State Department:

… on balance the gap in GHG intensity is likely to decrease over time.

But fine, let’s use EPA’s numbers. And then let’s throw in some from the Energy Information Administration (EIA), which projects the U.S. will emit 5,368 million metric tons carbon dioxide equivalent in 2013. Using that number over the 50 years EPA cites, total U.S. emissions would be 268,398 million metric tons – which means, according to EPA, the Keystone XL would represent 0.35 percent of U.S. emissions. And remember, EPA assumes that without the Keystone XL the oil sands crude will not be produced at all. Looking at other options the State Department found a reduction of:

…0.07 to 0.83 million metric tons carbon dioxide equivalent (MMTCO2e) annually if the proposed Project were not built…

Even using the high estimate, that would give us 42 million metric tons over EPA’s 50 years, or approximately 0.02 percent of U.S. emissions during that time period. Otherwise known as darn near zero.

Again, the State Department now has conducted four environmental reviews of the Keystone XL, and the project has cleared each one. In the most recent review, State concluded that the Keystone XL’s construction and operation would pose “no significant impacts” to the environment. More than four and a half years of federal scrutiny, four environmental studies - “no significant impacts.” The record is clear. EPA’s letter, asserting this minimal impact, is just a barely veiled attempt to inject more delay – delaying the job creation, the economic stimulation and the strengthened energy security that this project would bring. Given the wave of energy-related regulation that’s been building over at EPA, can’t say we’re surprised.


Mark Green joined API after a career in newspaper journalism, including 16 years as national editorial writer for The Oklahoman in the paper’s Washington bureau. Mark also was a reporter, copy editor and sports editor. He earned his journalism degree from the University of Oklahoma and master’s in journalism and public affairs from American University. He and his wife Pamela live in Occoquan, Va., where they enjoy their four grandchildren.