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Comments on KeystoneXL Supplemental Environmental Impact Statement


The Supplemental EIS is completely flawed and needs to be completely rewritten to consider the effects of this project on the Global Climate, and to consider additional Alternatives that might actually save the earth’s environment.


This statement appears to cover only local impacts and direct effects of the pipeline project. Admittedly, those local and direct effects are relatively minor; probably not much larger than those of similar large pipeline projects. In particular, Table 4.16.1, Summary of Potential Impacts, which focuses on the Construction, Operation, and Connected Actions is constructed so as to minimize the pipeline impacts. It ignores many impacts in the Connected Actions column. For example, the Connection Actions (CA) on Terrestrial Vegetation, Wildlife, Fisheries, Threatened and Endangered Species, Land Use, etc., Cultural Resources, Air Quality and Greenhouse Gases, all ignore the ongoing effects of Climate Change. 


The statement admits that the Connected Actions of Climate change were not evaluated. By not evaluating those effects, the entire point of an EIS was missed. When I studied Environmental Evaluation in the mid-70’s, my professor pointed out that in effect, everything in the Universe is connected to an action. The evaluator’s role is, through analysis, to determine which activities are sufficiently removed from the scope of the project to be ignored. It appears that in this case, the indirect effects of the Pipeline project have been ignored.


The original NEPA passed in 1969, in Section 102[C](v) [ , downloaded 4/21/2013] requires the inclusion in an EIS of “(v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.” You have included an obsolete and limited discussion of this from a prior EIS in Appendix N, but clearly the full EIS requires a thorough analysis of the effects of the pipeline project on Global Climate. By failing to completely address these effects with current data, you have not only failed to fulfill your responsibility under the law, but have also effectively failed to live up to your responsibilities to the future inhabitants of not only America but the entire world.


The irreversible and irretrievable commitments of resources have been adequately documented elsewhere, but include the following:

·         All of the resources that will be effected by global climate change, including a livable environment for a large portion of the world’s people.

·         The global ecosystem, which will go vast changes as the world’s temperature rises.

·         Changes in our agricultural system, which may be enhanced in some areas but will certainly change, and will be adversely affected in many areas.

·         The extinction of numerous species of plants and animals (possibly including Homo sapiens that would probably not go extinct if the climate environment stays relatively the same.


Global climate change, once it has reached a certain level, is irreversible within the probable lifetime of human civilization, which means that for us, it’s effects are effectively irretrievable.


The effect that the Keystone Pipeline project will have on the Earth’s climate is that it will contribute greatly to the increased CO2 levels by encouraging the production, export, and use of the Tar Sands oil in large quantities. The Tar Sands Oil will very likely not be mined if there is no way to get it to market. Of course the Canadians may still encourage it to be obtained and processed, but if it is not shipped to market through the US, it may not withstand the high political cost in Canada of shipping it to market through the West Coast. And there will most likely be a high political cost in both Canada and the US if this project, and the mining of Canadian Car Sands oil continue. That political cost may not show up for a generation, but once our grandchildren realize what we have done to them, they will not be happy.


Much of the discussion in the EIS focuses on the effect of such things as Climate change on the Project. Perhaps that is considered appropriate, but neglecting the effect of the Project on Global warming is not appropriate, and admitting that discussion defeats the entire purpose of the Environmental Statement.


The Project Alternatives discussed appear to be completely inadequate. They are based on the assumption that the Tar Sands mining will continue to produce oil and that the only alternatives are that the oil will be produced and will get to market some way. Another alternative should have been considered: that we actively oppose the production of the Tar Sands by investing in alternative methods of energy production, including wind, solar, natural gas, and conventional oil production from within the US. Even if those alternatives don’t seem to be politically feasible at present, they should have been considered in comparison to this project.


I note via a news article that you plan to require a FOIA request for us to see the comments on this EIS. Although I cannot afford myself to pay for the over 2 million comments expected, you should be aware that on a project of this much public interest, history will judge you badly if you fail to follow the usual procedure of publishing the comments.




Robert R. Stitt

Mobile 206-850-9863