On the proposed Keystone XL pipeline, EPA rated the adequacy of the State Department’s Draft Environmental Impact Statement (DEIS) as having “Insufficient Information.”

Yesterday was the last day to submit public comments to the State Department regarding the proposed pipeline that would transport 830,000 barrels of tar sands oil through the U.S. per day.

EPA’s Cynthia Giles, the Assistant Administrator for the Office of Enforcement, has submitted the agency’s public comment. They could have rated the adequacy of the impact statement three different ways: “Adequate,” “Insufficient Information,” or “Inadequate.” They rated it “Insufficient Information,” which means that they do not know enough to fully assess the environmental impacts of a tar sands pipeline traversing the continent.

Here are the reasons EPA said that State’s DEIS needs more work:

  • Increased carbon pollution: EPA acknowledged the DEIS’s attempt to do a life-cycle analysis of the pipeline’s emissions, which found that emissions from oil sands crude would be 81 percent higher than regular crude, or an incremental increase of 18.7 million metric tons of CO2 per year. EPA noted that “If GHG intensity of oil sands crude is not reduced, over a 50 year period the additional CO2 from oil sands crude transported by the pipeline could be as much as 935 million metric tons.” These statistics are alarming, yet EPA’s analysis did not stop there.
  • Not inevitable: Like other experts, EPA doubted State’s assurance that this tar sands oil would come out of the ground with the Keystone pipeline or without it:

    The market analysis and the conclusion that oil sands crude will find a way to market: With or without the Project is the central finding that supports the DSEIS’s conclusions regarding the Project’s potential GHG emissions impacts. Because the market analysis is so central to this key conclusion, we think it is important that it be as complete and accurate as possible.

    It then goes on to detail the ways in which this market analysis is incomplete: It uses outdated modeling, and the expense and infeasibility of rail shipping as an alternative to Keystone both need to be considered.

  • Pipelines don’t pump themselves: EPA recommends that renewable energy be used to power the pumping stations along the pipeline, because otherwise the constructed pipeline itself will actively emit GhG emissions.
  • Tar sands oil is particularly dirty to clean up: The EPA notes that diluted bitumen is very dense and sinks to the bottom of rivers and lakes. The 2010 Enbridge spill will require dredging, because normal cleanup methods do not suffice. The Keystone pipeline would be 36 inches in diameter — larger than the pipe that leaked 20,000 barrels of oil in the Enbridge spill. EPA notes that dilbit contains some very toxic materials “such as benzene, polycyclic aromatic hydrocarbons (PAHs), and heavy metals” that “could cause long-term chronic toxicological impacts” to wildlife. EPA recommends including a seriously revamped and rethought response plan as conditions before any permit is issued to build a pipeline.
  • Who needs drinking water?: Though Keystone’e proponents received praise for moving the original route away from the Sand Hills, it still crosses the Ogallala Aquifer. The EPA notes there is another way: “The alternative laid out in the DSEIS that would avoid the Ogallala Aquifer is the I-90 Corridor Alternative, which largely follows the path of existing pipelines.” There were additional alternatives that State’s EIS did not address, and EPA asked it to do so.

That does not sound like the a “no-brainer” that Keystone’s advocates have described. That sounds exactly like the nation’s top environmental cops on the beat responding to an assessment of a project made by a firm being paid by the pipeline’s owner.