State's Keystone XL Climate Equivocation Is Nonsense

The fight against the proposed Keystone XL tar sands pipeline has been a long one. It has involved people around the world. It has touched on issues critical to the globe’s health and critical to human survival. Few single pieces of proposed infrastructure encapsulate so completely all that is wrong—in 2017—with the world’s continued exploitation and reliance on new sources of fossil fuel. This reliance is one of the most significant drivers of climate change, and it is on the issue of climate change that the Trump administration’s recent actions on Keystone XL took yet another inexplicable turn. Even as the State Department rushed to reverse its previous rejection of Keystone XL on the basis of dated analysis and circular reasoning, a concurrent environmental review by the same agency acknowledged that tar sands are even more carbon intensive than previously thought.

In the State Department’s “record of decision” justifying their issuance of Keystone KL’s cross-border permit, the Department wrote:

In the 2015 Decision, the Department determined that approval of the proposed Project at that time would have undercut the credibility and influence of the United States in urging other countries to address climate change. Since then, there have been numerous developments related to global action to address climate change, including announcements by many countries of their plans to do so. In this changed global context, a decision to approve this proposed Project at this time would not undermine U.S. objectives in this area. Moreover, a decision to approve this proposed Project would support U.S. priorities relating to energy security, economic development, and infrastructure.

If you’re saying to yourself—“What?”—you’re not alone. The paragraph is light on detail and short on logic, but it appears to be saying: Because the rest of the world decided to act on climate change via the Paris Agreement, and because the United States helped push that action, our credibility is no longer at stake. And besides, everyone else is taking care of this problem, so we’re all good.

What’s even stranger is that the State Department also appears to have found—this time around—that Keystone XL’s climate impacts could be considerably worse than it previously thought. In the 2014 environmental impact statement that was used by the Obama State Department to reject the pipeline’s cross-border permit, the Department wrote:

WCSB crudes are generally more GHG intensive than other heavy crudes they would replace or displace in U.S. refineries, and emit an estimated 17 percent more GHGs on a lifecycle basis than the average barrel of crude oil refined in the United States in 2005.

In its 2017 record of decision, the Department repeats this language, but goes on to say this:

GHG lifecycle emissions analysis performed by the Department after publication of the Supplemental EIS [for another tar sands crude oil pipeline, Enbridge’s proposed Alberta Clipper (Line 67) expansion] estimates that GHG emissions from WCSB crude may be five to 20 percent higher than previously indicated. [That analysis] places emissions per barrel of WCSB at 584 kg C02-eq per barrel, compared to approximately 485-555 kg C02-eq per barrel to in the Supplemental EIS for the proposed Project.

The net impact of this upward revision in potential climate pollution means that the annual lifecycle emissions of the tar sands moved by Keystone XL could be 177 million metric tons of CO₂e. That’s equivalent to the annual emissions of 37 million passenger vehicles or 51 coal-fired power plants. It also moves the high-end estimate of the project’s emissions up by 9 million metric tons per year.

That’s quite a revision and it does a lot to justify the State Department’s previous position on the project, which rested, in part, on the project’s impacts on climate change. Here’s the Department in 2015:

The broad perception of the oil that would be carried by the proposed Project is that it would be . . . more GHG-intensive over its lifecycle than alternate sources of crude . . . . This perception is supported by the findings in the SEIS. Whether or not that oil would still find other transport to market in the absence of the proposed Project (that complex issue is analyzed in the Supplemental EIS), the general perception is that a decision to approve the pipeline would pave the way for the long-term and intensive extraction and importation of that oil into the United States. Issuing a permit for the proposed Project would thus be understood at this time as a decision to facilitate particularly GHG-intensive crude imports into the United States for the long term . . .

This statement revealed several key truths about Keystone XL. The first is that with oil prices continuing to trade well below the $75/barrel threshold that most tar sands producers need to see to make a profit, there is little question that “other transport” modes are not viable. In this case, those modes were generally assumed by the State Department to be crude-by-rail. But recent analysis has shown just how bad a bet that transport option is for tar sands producers, especially if they are trying to reach Gulf Coast refineries.

The second truth here is that one of the key reasons Keystone XL is such a roadblock in the fight against climate change is the problem of carbon “lock-in.” This phenomenon concerns the long-term impact of decisions made today and the fact that those decisions may continue to impact emissions 50 or more years down the road. In the case of Keystone XL, the project would have a projected useful live of at least 50 years, and the expanded tar sands production it would facilitate would be expected to produce for that entire period as well. Unlike other sources of oil, tar sands projects require huge up-front capital expenditures and can cost producers more to shut down, even when oil prices are so low that they’re losing money on each barrel sold. In short: approving Keystone XL would lock the annual release of 177 million metric tons of CO₂e into the global emission budget through at least 2070.

These inconsistencies, and the lack of renewed formal analysis they received by the Trump State Department in its rushed review of Keystone XL, highlight some of the reasons NRDC and its allies are taking the State Department to court. The Department’s decision to grant this permit was based on a document written in 2013 and finalized in January 2014 that was, at the time, already flawed. The outright refusal to take any new public comment on the pipeline following President Trump’s executive action bringing the pipeline back to life only deepens those flaws.

By approving Keystone XL’s cross-border permit, alongside rollbacks of other critical climate change mitigation policies, the Trump administration is ceding American global leadership on one of the greatest challenges of our time. And it moves the United States closer to the back of the line in the race to develop and dominate the alternative energy sector. It’s hard to see how any of this will make us safer or more prosperous, the big promises guiding this short-sighted approval that is all risk and no reward for the American people.