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The US State Department is accepting comments on the Draft Supplemental Environmental Impact Statement (Draft SEIS) for the Proposed Keystone XL Pipeline. You can comment at their website through November 18th.

Please submit comments if you can.

From the Center for Biological Diversity: This time-lapse video shows pipeline incidents from 1986 to 2013, relying on publicly available data from the federal Pipeline and Hazardous Materials Safety Administration. Only incidents classified as “significant” by the agency are shown in the video. “Significant” incidents include those in which someone was hospitalized or killed, damages amounted to more than $50,000, more than 5 barrels of highly volatile substances or 50 barrels of other liquid were released, or where the liquid exploded or burned. According to the data, since 1986 there have been nearly 8,000 incidents (nearly 300 per year on average), resulting in more than 500 deaths (red dots on the video), more than 2,300 injuries (yellow dots on the video), and nearly $7 billion in damage. Since 1986 pipeline accidents have spilled an average of 76,000 barrels per year or more than 3 million gallons. This is equivalent to 200 barrels every day.

Here are my comments (posted 10-31-19):

According to the U.S. Energy Information Administration, the burning of fossil fuels was responsible for 76 percent of U.S. greenhouse gas emissions in 2016. These gases contribute to the greenhouse effect and could lead to potentially catastrophic changes in the Earth’s climate.

As global concern rises on the increasingly deadly results of climate change, it has become clear that we must wean ourselves from fossil fuel dependency and move to cleaner forms of energy generation. The public outcry and protest against KXL shows that not all are glittery-eyed deceived by the idea of money for a few. Instead citizens are focused on protecting life-giving resources like clean land, water, and air essential not only to human life, but all life. That some would sacrifice clean water for money is not a reason to approve any new fossil fuel infrastructure. The protection for people must come before oil profits. The time is NOW to end all fossil fuel infrastructure development.

It is clear from the ongoing releases in the ExxonMobil case happening now in New York that the fossil fuel industry has covered up their contributions to global climate change. That they have made decisions in full knowledge of the devastating effects they would have on humans is criminal and we cannot continue to support any fossil fuel development lest we risk complete human extinction. We have already reduced our biodiversity of mammals by 60% and insects by anywhere from 10-80% and this biodiversity is critical to continued human life. All is interconnected.

“The Department invited the following Indian tribes involved in the Keystone XL Pipeline Programmatic
Agreement to participate in the NEPA process for this SEIS.” How many tribal members were involved with the process? Was easy access provided to each tribe to participate? Were meetings taken to their locations? It is insulting to request participation without providing easy access to those whose treaty rights are potentially being violated by the decisions made. Perhaps Tribal non-participation indicates opposition. True consultation is not done via an invitation-only approach.

“Operations • During aerial surveillance, aircraft will maintain at least 1,000 feet of elevation.” How can accurate assessments of flora and fauna be done at this altitude?

“The Department conducted a robust analysis of alternatives in both the 2014 Keystone XL Final SEIS and in the earlier 2011 Keystone XL Final EIS. This included consideration of transportation of crude oil by rail, trucking or use of existing pipelines, as well as use of alternative energy sources and energy conservation. Ultimately the Department dismissed each of these alternatives from detailed analysis as they failed to meet the purpose and need.” Until robust programs are developed by our government to codify – or even begin to promote – conservation, how can we guarantee that this path will not help us meet needs? It seems convenient to simply dismiss alternative energy and conservation without giving concrete effort along these lines to find another way. This work is necessitated by NEPA. The National Environmental Policy Act (NEPA) was enacted to: declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality.

Regardless of the global outcry for oil, we must end our dependency as the burning of fossil fuels is systematically eliminating all life on the planet.

I insist on denial of this KXL project as well as any new fossil fuel infrastructure projects.

And, because I hit a character limit, I also submitted this:

In light of this week’s 380,000+ gallon spill (photo above), this section of the KXL SEIS is extremely questionable (my highlight added):

“S.7.2 Potential Effects of the Proposed Project from Accidental Releases

Impacts under normal operations would be negligible to moderate. However, there is potential for environmental impacts from the proposed Project if an accidental or otherwise unexpected release of crude oil from the Keystone XL pipeline or facilities occur. These potential impacts are not likely to be significant because (1) the risk of an accidental release is unlikely; (2) Keystone would use continuous monitoring systems and automatic shutoff valves to quickly identify a leak or rupture and halt pumping immediately upon detection of pressure fluctuations; and (3) prompt implementation of Keystone’s response plan should mitigate effects.”

Was this failing portion of the pipeline also operating under this same assumption of “unlikely” spill per its Environmental Impact Statement?

All pipelines leak. And most of them eventually spill. Often with quite severe environmental impacts. The lack of scrutiny given to the statements made in the submitted EIS and the subsequent spills/leaks on any given pipeline is astounding. Use of words such as “unlikely”, “minimal”, and “negligible” are deceptive and preclude true assessment of the dangers to our environment.

“Keystone will prepare and implement a project-specific SPCC Plan” Why is this document not required as a part of this EIS? Will this Spill Prevention, Control, and Countermeasures Plan be available for public scrutiny? When?

It seems that, even with the amazing amount of Environmental Review (ER; including Environmental Impact Statements and Environmental Assessment Worksheets) done for projects like this, we continue to see degradation of our environment as industry continues to destroy natural places. This alone should make suspect the entire process of Environmental Review as an effective tool for evaluating these types of projects.

I implore those with authority to find effective ways to determine a full accounting of accurate risks, as evaluated by experts with the industry, scientific, and environmental knowledge needed for proper evaluation, prior to implementing any new fossil fuel infrastructure project.

At present, with no effective program in place, I insist on denial of this KXL project, along with all other new fossil fuel infrastructure porjects.

Please submit your comments today.

Photos courtesy of: Native News Online and Grand Forks Herald.