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Greenhouse Gas Emissions: EPA Cries Foul on Keystone XL & Gov't Forecasts Fall Short

Two news items surrounding greenhouse gas emissions moved over the past week. One on the trajectory of said emissions from government number-crunching. The other on what the proposed Keystone pipeline might mean for emissions.

We start with Keystone. On Monday the Environmental Protection Agency weighed in [pdf] on the Keystone XL pipeline project. Its conclusion? ”Insufficient information.”

A Hole in Proponents’ Arguments for the Proposed Pipeline

Remember the draft supplemental environmental impact statement* on TransCanada’s proposed Keystone XL Pipeline that would allow crude from Canadian tar sands to flow to U.S. Gulf Coast refineries? Prepared for the State Department, which must OK the project because it crosses an international border, the draft statement concluded with music to the ears of the pipeline’s proponents: “The proposed project … would [pose] no significant impacts to most resources along the proposed Project route.” (See my post for more on the draft statement.)

After it was released on March 1, interested parties and agencies had 45 days to submit comments on the draft and the pipeline, which has become one of the most contentious environmental issues in Obama’s presidency. That public comment period ended at midnight on Monday, and among the reported tens of thousands of comments (some say over a million) that poured in during the comment period was a seven-page reaction from the Environmental Protection Agency submitted just under the wire.

The agency’s assessment in short: “Based on our review, we have rated the [draft supplemental environmental impact statement] DSEIS as E0-2 (‘Environmental Objections – Insufficient Information’).”

Need help on the government-speak? E0-2 or Environmental Objection #2 refers, as indicated, to an objection on environmental grounds because of “insufficient information” or because, as not indicated, the EPA has “identified new reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action.” Did you get all that? If not, basically EPA is saying that it doesn’t buy the State Department’s assessment because it failed to consider all the options.

One Sticking Point: Estimated Emissions from Tar Sands Oil

A major EPA objection to the impact statement concerned the State Department’s assessment that the pipeline itself, as a conduit for transporting bitumen from Canadian tar sands, would have little impact on greenhouse gases. The stated reasoning for such a conclusion: Even if the pipeline were not built, the tar sands oil production would be largely unaffected as other means of transport (e.g., rail, other pipelines) would be used to bring the heavy crude to market.

EPA was not convinced:

“We note that the discussion in the DSEIS regarding energy markets, while informative, is not based on an updated energy-economic modeling effort. The DSEIS includes a discussion of rail logistics and the potential growth of rail as a transport option, however we recommend that the Final EIS provide a more careful review of the market analysis and rail transport options. … recognizing the potential for much higher per barrel rail shipment costs than presented in the DSEIS. This analysis should consider how the level and pace of oil sands crude production might be affected by higher transportation costs and the potential for congestion impacts to slow rail transport of crude.”

EPA also noted that the State Department’s evaluation of pipeline alternatives is not “sufficient to enable a meaningful comparison to the proposed route and other alternatives.” In addition, the agency reported that it would like to see a more rigorous analysis of the existing pipeline corridor, as it avoids not only the Sands Hills aquifer (which was one of the sticking points of the first proposed route) but the Ogallala aquifer as well. (See related interactive map of the route: “Keystone XL: Mapping the Flow of Tar Sands Oil.”)

What’s Comes Next?

So what happens now is more hurry up and wait. The release of the draft environmental impact statement and the conclusion of the public comment period following that release means that the preparation of a final impact statement can now officially begin. That “Final Supplemental EIS,” said State Department spokesman Patrick Ventrell, would include “additional analysis and incorporate public comments received on the Draft SEIS.” As for all those many public comments, State has promised to publish each and every one. There’s no word yet on when.

And remember all this is for just the environmental assessment. In all, eight federal agencies [pdf] will need to weigh in on the project before State renders its decision.

Whither U.S. CO2 Emissions?

While we’re on the subject of carbon dioxide (CO2) emissions. it is relevant to note that the Energy Information Administration (EIA) has begun releasing its Annual Energy Outlook for 2013. One item published last week was the forecast for U.S. energy-related CO2 emissions through 2040. This projection along with EIA’s past projections between 2004 and 2012 is illustrated below.

CO2 Forecasts Plus Copenhagen Commitment

AEO: Annual Energy Outlook, from EIA’s archived forecasts issued in a given year and its latest, AEO 2013 (Additional info here.) U.S. commitment in the Copenhagen Accord [pdf]

There is certainly good news here. Since 2004, the EIA’s estimate for future U.S. emissions has consistently fallen for each projection. As discussed previously (see here, here and here), this decrease can be attributed to a number of factors including the global recession, fuel-switching away from coal and petroleum and toward natural gas, decreasing energy intensity, milder winters, and so on.

But lest we get carried away congratulating ourselves, the news from the EIA’s 2013 projection is not all roses. While U.S. emissions have been falling since the economic downturn of 2008, EIA projects they will begin a modest upturn in 2017 that will continue through 2040.

And even given the sizable (some might say remarkable) decrease in our projected emissions over the next few decades, as compared to earlier projections, the current forecast falls quite short of the emissions reductions President Obama committed to as part of the Copenhagen Accord [pdf], as illustrated in the above graphic. (See also here.)

Perhaps that’s one of the reasons EPA is concerned about the potential emissions from tar sands. Of course the State Department’s answer could be that if EIA just keeps ratcheting down its emissions projections, maybe we’ll meet our emissions commitment without even trying. So why worry about a little bit of extra greenhouse gas emissions (on the order of about 19 million metric tons annually, according to EPA estimates) from tar sands? Why indeed.


End Note

* Because of a previously proposed route for the pipeline, which had its own environmental impact statement (which was ultimately rejected), the statement issued in March is a “supplemental” environmental impact statement [pdf]. A final supplemental statement will be issued after more analysis and review.

Bill Chameides's picture

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John Miller's picture
John Miller on Apr 26, 2013 9:19 pm GMT

The EPA’s 19 MMT/yr. carbon dioxide equivalent increase overstates emission impacts compared to many other estimates of actual impacts, including my own.  But, let’s put this debate on a global basis, which the EPA has yet to adjust its thinking towards (they historically only deal with local environmental impacts/concerns).  Assuming the EPA’s 19 MMT/yr. carbon emission increase were reasonably feasible, this level of added carbon represents an increase of world total carbon emissions of about 0.05% based on DOE/EIA IEO 2011 projection for CY2016 (the Keystone XL feasible startup if the Administration were to approve the pipeline within the next year +/-).  Or if just based on China’s actual-projected carbon emissions, the 19 MMT/yr. only represents 0.20% increase in China’s total CY2016 emissions.  Statistically the 19 MMT’s is not very significant, particularly when the accuracy (5 – 19 MMT) is taken into account.

If one were suspicious of the EPA’s motives, one might interpret this latest action as just a continuation of the Administration’s delaying tactics or strategy to defer the final decision until the next Administration.  It’s time for this Administration to make a decision and quit developing more irrelevant issues to infinitely defer the final decision.  The Canadian’s would be most appreciative so they can stop wasting their time and begin developing their other options to the U.S. Keystone XL route.  Of course, an alternate route will have zero benefit for the U.S. and probably significant benefit for China.  Oh, by the way, did the EPA happen to consider the added carbon emissions of the alternative routing options to the Keystone XL (once again, a global focus issue).

Rob Dekker's picture
Rob Dekker on Apr 27, 2013 10:22 am GMT

John Miller said “The EPA’s 19 MMT/yr. carbon dioxide equivalent increase overstates emission impacts compared to many other estimates of actual impacts, including my own”.

John, that number is from the State Department’s SEIS, not from the EPA.

For starters, since the State Department’s numbers are based on actual data, while your analysis is based on a model (GREET), this may be a good opportunity for you to explain where your own analysis went wrong.

Second, the EPA only emphasizes the number, since the State Department’s DSEIS conclusions hand wave this number into insignificance by assuming (even using the word “perhaps”) that rail transport will compensate most of the capacity at some point in the future, and relating that reduced influence to a future TRIPLED projected production rate of bitumen extraction, to 5 mbpd in 2030.

So now we are talking about 114 MMT/yr incremental emissions from the tar sands in 2030.

Of course, one of the main issues with the Keystone XL is not so much the “incremental” energy used (mostly by burning Natural Gas during processing) but the carbon released when we actually burn the refined bitumen product, and, at an overall carbon footprint of 600 kg CO2/barrel, will (with a 5 mbpd projected bitumen production) be around 1100 Mton/yr in 2030.

And the real issue is that there are enough fossil bitumen deposits in Alberta to increase atmospheric CO2 by some 200 ppm, which, when can single handedly return this planet’s climate systems back to the early Pliocene. 

So, by which mechanism will we leave a significant part of these bitumen IN THE GROUND, even though free market forces will want to extract them ?

Jessee McBroom's picture
Jessee McBroom on Apr 27, 2013 3:11 pm GMT

Given the stress and strain on our aging infrastructure and the melting of the Arctic Ice Cap; maybe Canada would find it easier to put a pipeline to an Eastward port and refinery to indulge China’s’ thirst for oil. They don’t want the tourism to Vancouver to suffer costing them tourist dollars. Why are we so quick to jeopardize our own Tourism through a very large swath of our Eastern half. Not to mention our watersheds in the Eastern half.

John Miller's picture
John Miller on Apr 27, 2013 10:59 pm GMT

Rob, it does not matter where the 19 MMT number was derived it’s on or beyond the upper extreme of reasonable estimates.  It probably ignores re-veg’ing the open pit mines and assumes all the hydrocarbons including those not extracted from the residual oil sands (and re-buried), are 100% decomposed, which is an unreasonably high assumption.

Your 200 ppm increased atmospheric carbon dioxide concentration emission estimate also appears to be a bit high.  Canada roughly has 175 Billion barrels (BB) of proven crude reserves, compared to total world of about 1,500 BB.  Using your 200 ppm estimate means the total world crude reserves will increase atmospheric carbon dioxide concentrations by (200 x (1500/175) =) 1700 ppm (+/-) within about the next 14 years?? (based on EIA IEO 2011 oil consumption projections).  This does not include the impact of coal which will possibly double this value again.  Sounds a little high perhaps?

Rob Dekker's picture
Rob Dekker on Apr 28, 2013 6:32 am GMT

John, “It probably ignores re-veg’ing the open pit mines and assumes all the hydrocarbons including those not extracted from the residual oil sands (and re-buried), are 100% decomposed, which is an unreasonably high assumption.”

I think you are confused. The 19 Mton/year number refers only to the emissions resulting from ‘processing’ tar sands into bitumen (mostly by burning Natural Gas), and thus has nothing to do with re-veg’ing or the amount of residual oil sands that get re-buried or decomposes.

Regarding the total deposits of fossil carbon in the Canadian tar sands, the 2010 World Energy Council report on energy resources states “The three Alberta oil sand areas, Athabasca, Peace River, and Cold Lake, together contain 1.73 trillion barrels of discovered bitumen in place”

1.73 trillion barrels of bitumen translates to approximately 200 ppm increase in atmospheric CO2, which will bring the planet back to the climate systems of the early Pliocene or late Miocene, if all extracted.

And that is only from a single source (Alberta). 

The total amount of discovered fossil fuel sources on this planet is much larger than that, and if we would extract all of it, we will simply cook this planet. 

So the question again is: by which mechanism will we leave a significant part of these bitumen IN THE GROUND, even though free market forces will want to extract them ?

John Miller's picture
John Miller on Apr 28, 2013 4:50 pm GMT

Rather transition this debate to the energy intensity of ‘synbit’ and ‘dilbit’ crudes vs. available world alternatives, and the issue of ‘proven’ and ‘unproven’ oil reserves possibly located in individual countries and on a global basis I suggest we continue this conversation outside this post.  If you want to discuss these details further, contact me directly.

James Thurer's picture
James Thurer on Apr 30, 2013 6:10 pm GMT

“And the real issue is that there are enough fossil bitumen deposits in Alberta to increase atmospheric CO2 by some 200 ppm, which, when can single handedly return this planet’s climate systems back to the early Pliocene.”

Exactly.  That is why this objection to the XL pipeline is ridiculous.  The projected total production to be transported from Alberta through the XL pipeline is 8 billion barrels over a 40 year life.  This is about 1/2 of 1% of the 1.8 trillion barrel figure that is cited when projecting increasing atmospheric CO2 by 200ppm.

There are three simple realities here:

1)  The great bulk of the CO2 release associated with the XL pipeline is attributable to the consumption of the products, not their production.  The most effective way to reduce CO2 release associated with petroleum products is to reduce their consumption.  Blocking the XL pipeline will not achieve this.

2)  If the pipeline is not built, then the products will be produced from some other source, and the net reduction in CO2 release will be inconsequential.

3)  The 200ppm figure that is cited in association with exploiting the entire 1.8 trillion barrels in place in the Alberta tar sands has nothing to do with the volume to be transported through the XL pipeline. 



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