Cynthia Giles, Assistant Administrator for Enforcement and Compliance Assurance, Environmental Protection Agency (EPA), in her letter on the subject addressed to the US Department of State (The Department), on April 22, 2013, stated that we commend the Department of State’s efforts to estimate the lifecycle greenhouse gas (GHG) emissions associated with oil sands development and the Proposed Project, to analyze the effect of the Project on Canadian oil sands production and to consider measures to reduce GHG emissions.  As recognized by the Department of State’s Draft Supplemental Impact Statement (DSEIS), oil sands crude is significantly more GHG intensive than other crudes, and therefore has potentially large climate impacts.  The DSEIS reports that lifecycle GHG emissions from oil sands crude could be 81 percent greater than emissions from the average crude refined in the US – In 2005 on a well-to-tank basis, and 17 percent greater on a well-to-wheels basis.  This difference may be even greater depending on the assumptions made?

The incremental emissions from oil sands crude transported by the Project would therefore be 18.7 million metric tons C02-e (carbon dioxide equivalent) per year when compared to an equal amount of US average crudes, based on the Project’s full capacity of 830,000 barrels of oil sands crude per day.  To place this difference in context, we recommend using monetized estimates of the social cost of the GHG emissions from a barrel of oil sands crude compared to average US crude.  If GHG intensity of oil sands crude is not reduced, over a 50 year period the additional C02-e from oil sands crude transported by the pipeline could be as much as 935 million metric tons.  It is this difference in GHG intensity -between oil sands and other crudes -that is a major focus of the public debate about the climate impacts of oil sands crude.

It was further stated that although the DSEIS describes the GHG intensity of oil sands crude, the DSEIS nevertheless concludes that regardless of whether the Project permit is approved, projected oil sands production will remain substantially unchanged.  This conclusion is based on an analysis of crude oil markets and projections of oil sands crude development, including the potential for other means of transport to bring oil sands crude to market.  One of the alternative transport possibilities discussed in the DSEIS is the potential construction of other pipelines.  As part of this discussion, the DSEIS appropriately recognizes that there is uncertainty about when, if ever, additional pipelines will be built.  In light of these uncertainties, the DSEIS examines options for transporting oil sands crude by rail, and concludes that scaling up transport by rail is logistically and economically feasible, and that market forces will result in additional rail transport of oil sands crude if the Project is not built. It is this finding that supports the DSEIS’ overall conclusion that approval of the permit will not by itself substantially affect GHG emissions or contribute to climate change.


Following the letter and as a matter of policy, in addition to its environmental analysis of the Proposed Project in the United States, the Department has included information regarding potential impacts in Canada.  In so doing, the Department was guided by Executive Order (EO) 12114, which stipulates the procedures and other actions to be taken by federal agencies with respect to environmental impacts outside of the United States.  Accordingly, the Canadian government conducted an environmental review of the portion of the proposed pipeline in Canada.  As a result, and consistent with EO 12114, the Department did not conduct an in-depth assessment of the potential impacts of the Canadian portion of the Proposed pipeline.

Canada’s National Energy Board’s (NEB) Environmental Screening Report (ESR) determined that with the implementation of Keystone’s environmental protection procedures and mitigation measures, and with the NEB’s conditions and recommendations, the Proposed Keystone XL pipeline in Canada was not likely to cause significant adverse environmental effects.  In addition, it is NEB’s position that the Proposed pipeline would not likely result in significant adverse cumulative environmental effects in Canada in combination with other projects or activities that have been or will be carried out.

Potential impacts of the proposed pipeline on Aboriginal people were also considered by NEB.  In their review, NEB found no specific evidence of Aboriginal use over the proposed pipeline route and no evidence that there would be impacts on areas where traditional cultural activities are currently carried out. NEB noted Keystone’s commitment to ongoing Aboriginal consultation and engagement during construction and operation of the proposed pipeline, and NEB imposed conditions to this effect.

Furthermore, the province of Alberta, Canada, has enacted legislation that regulates GHG emissions; the legislation requires that large emitters report their emissions and take mandatory actions to reduce emissions. Industry emissions that are greater than 50,000 tons must be reported annually using a specified gas reporting standard, and the emissions intensity of emissions greater than 100,000 tons must be reduced by 12 percent through the following mechanisms:

  • Improving operations;
  • Purchasing offsets—the purchases of offsets are regulated and can be purchased from sectors that have voluntarily reduced their emissions in Alberta.  Offsets are created using protocols approved by the government of Alberta and must be verified by an independent third party;
  • Contribute to the Climate Change and Emissions Management Fund—firms may pay $15 per ton of emissions into the fund in order to meet the 12 percent reduction target.  The fund will assist in achieving the goals of Alberta’s Climate Change strategy to support the development and application of transformative technologies; and
  • Purchase or use Emissions Performance Credits—these credits are generated by facilities that have achieved the 12 percent mandatory reduction.  Emissions Performance Credits may be sold to other facilities or banked for future use.  However, they can only be used once and not in the same year they are generated (Environment and Sustainable Resource Development 2013).


The Department evaluated the potential construction and operational impacts of the Proposed Project and alternatives across a wide range of environmental resources. The analysis discusses public and agency interests and concerns as reflected in the submissions received during the scoping period and on the 2013 Draft DSEIS.

For the lifecycle GHG emissions assessment, information, data, methods, and analyses used in this discussion are based on information provided in the 2011 Final Environmental Impact Statement (EIS) and the 2013 Draft Supplemental EIS, as well as new information relevant to environmental concerns that has become available since the Final EIS and DSEIS publication.  Here is a graph which illustrates relationship between climate change and the Proposed project:


The key elements considered regarding climate change are as follows:

  • The GHG emission impacts of the Proposed Project have been discussed with reference to other GHG emission levels and how these cumulatively contribute to climate change.  Direct and indirect emissions associated with the Proposed Project, as well as those of alternative actions, contribute to cumulative global GHG emissions together with those of other past, present, and reasonably foreseeable future actions. GHG emissions differ from other impact categories discussed in this Final Supplemental EIS in that all GHG emissions of the same magnitude contribute to global climate change equally regardless of the source or geographic location where they are emitted;
  • Information on GHG emissions associated with the production of the oil sands crude oil in Canada are discussed in the context of total Canadian emissions, as reported by Environment Canada;
  • An analysis was performed to evaluate the potential impacts of climate change on the Proposed Project construction and operations.  A number of sources were reviewed and cited as part of this analysis, and used to establish the projected climate changes for the Proposed Project lifetime, comprising increased summer temperatures and temperature extremes, as well as increased annual precipitation, including more severe storm events.  Climate conditions during the 1-to 2-year construction period would not be expected to differ much from current conditions.  Keystone has represented that the Proposed Project is designed in accordance with US Department of Transportation (USDOT) regulations and the Pipeline Hazardous Material Safety Administration (PHMSA) Special Conditions, Potential Releases and Pipeline Safety, and that these design standards are sufficient to accommodate the projected different future conditions resulting from climate change; and
  • Consideration has also been given to the impacts and effects that have been presented in this Final Supplemental EIS that are attributable to the Proposed Project, and whether the projected climate changes could further exacerbate or influence these identified impacts and effects.


The construction phase of the Proposed Project would result in GHG emissions arising from the following sources or activities:

  • Clearing of land in the Proposed right-of-way (ROW) via machinery and open burning on some portions of disturbed land (0.5 percent of the land projected to be disturbed, based on information received from TransCanada Keystone Pipeline, LP (Keystone);
  • Backup emergency generator engines running at eight construction camps;
  • The contractor yards would likely have small trailer offices connected to the grid.  In comparison to the contractor camps, indirect GHG emissions associated with electricity usage at the contractor yards or elsewhere would be small and were not estimated;
  • Indirect (off-site) electricity usage at the eight construction camps;
  • On-road and non-road vehicles used for the construction of the Proposed pipeline; and
  • On-road and non-road vehicles used for the construction of the pump stations.

For the entire duration of the construction phase, the estimated GHG emissions amount to 244,153 metric tons of CO2e.

The pipeline would be constructed in Montana, South Dakota, and Nebraska simultaneously in 10 construction spreads, of which each would require an average of 6 to 8 months to complete.  Eight construction camps, which would house personnel working on the construction of the Proposed Project, would be powered by electricity from the local utility (grid).  During upset conditions when commercial power supply is interrupted (assume 500 hours per camp), one 400kilowatt backup emergency generator engine per camp would be used.  On-road vehicles such as various types of diesel-powered trucks and non-road vehicles such as diesel-powered bulldozers and loaders would be used throughout the entire construction phase along the pipeline route and at the 20 pump stations in Montana, South Dakota, Nebraska, and Kansas.

Keystone would minimize the extent of land clearing for ROWs and expect that contractors would maintain construction equipment and vehicles in accordance with manufacturer’s recommendations.  Keystone would implement the following measures to minimize production of GHGs during construction:

  • Contractors would be required to ensure that motorized equipment is operating only when required (no unnecessary idling); this requirement would be reinforced during training of the construction workforce and during construction;
  • Utilization of construction camps with associated contractor yards would reduce the overall number of personal vehicles being operated to drive to and from the construction yards each day;
  • Contractors would utilize state of the art equipment to increase energy efficiency and effectiveness;
  • Throughout construction, contractors would be required to conduct regular maintenance and inspections of their equipment. Deteriorated parts would be required to be promptly repaired or replaced;
  • Keystone would limit the construction disturbance and land clearing to the minimum necessary to safely build the Proposed Project; and
  • Following construction, areas disturbed during construction would be re-vegetated as soon as possible.


During the operation phase of the Proposed Project, GHG emissions would arise from both direct and indirect sources. Direct operating emissions would include minimal fugitive CH4 emissions at connections both along the main proposed pipeline and at the pump stations.  These fugitive CH4 emissions would be emitted from approximately 55 intermediate mainline valves along the pipeline route and from the 20 pump stations.  Emissions from the use of maintenance vehicles (at least twice per year) and aircraft for aerial inspection (at least once every 2 weeks) during the Proposed Project operations are expected to be negligible.  Indirect operating emissions from the Proposed Project would be associated with electricity generation needed to power the pump stations.

The Proposed Project includes 20 pump stations: six in Montana, seven in South Dakota, five in Nebraska, and two in Kansas.  Each pump station would consist of four to six pumps driven by electric motors (exp. Energy Services Inc. 2012). The pumps are rated at 6,500 horsepower (hp), and annual electricity usage from pump stations in Montana (1,274,317 megawatt-hour(s) per year [MWh/year]), South Dakota (1,486,703 MWh/year), Nebraska (1,061,931 MWh/year), and Kansas (424,772 MWh/year) were provided by Keystone.  This electricity usage has been updated from that assumed in the Draft Supplemental EIS, in which pumps were assumed to run continuously; updated information indicates that pumps would run at less than full load.

Using USEPA’s e-GRID factors for the regions in which the pump stations would be located, the indirect operating emissions for the Proposed Project are estimated to be 1.44 MMTCO2e. This calculated GHG emissions value assumes that the pumps along the pipeline alignment operate at their full hp capacity (i.e., 6,500 hp).  This is a conservative assessment because in reality very few pumps would reach their motor hp. If it was assumed that the pumps would operate on average at 90 percent of their design condition loading, and the variable speed drive would operate the pump at partial load on average 85 percent, an operating hp of 3,569 would be obtained. The GHG emissions with the pumps operating at this hp would be 0.79 MMTCO2e per year.

To put these emissions into context, the annual CO2e emissions from the Proposed Project are equivalent to emissions from approximately 300,000 passenger vehicles operating for 1 year, or 71,928 homes using electricity for 1 year.  The GHG emissions associated with operation of the connected actions are deemed minimal relative to the Proposed Project, and have not been calculated.

Keystone would implement the following measures to minimize energy consumption and production of GHGs during operation of the Proposed Project:

  • Contractors would be required to conduct regular maintenance and inspections of their equipment, including pumps associated with pump station operations. Deteriorated parts would be required to be promptly repaired or replaced;
  • The Proposed Project’s pump station design incorporates state of the art equipment that has been engineered and manufactured to a high level of energy efficiency. The 6,500 hp induction motors are in excess of 97 percent efficient, compared to motors used in the existing Keystone pipeline, which are 96.1 to 96.6 percent efficient.  Each pump station includes a variable frequency motor drive, which is rated at 96 percent or better in efficiency.  This electronic equipment provides precise flow/speed control to allow the pump to operate at the point of peak efficiency and eliminates the need for a pressure control valve, which would otherwise waste pressure and, therefore, energy.  This equipment also has the added benefit of minimizing current in-rush during motor start; and
  • The main line pumps of the pump station have been tested at 91 to 92 percent efficiency, compared to a best efficiency range between 87.1 to 88.6 percent for the existing Keystone pipeline pumps.  This high efficiency rating is achieved through a specialized manufacturing process, producing highly polished internal pump components. In addition, many of the Proposed Project pump stations would have power factor correction capacitor banks installed. These banks also improve the efficiency of the utility power system to a 95 percent power factor.

Electrical power would be supplied to the pump stations by local cooperatives or utilities that determine how the power would be generated, including renewable sources (such as wind and solar power, which result in fewer GHG emissions than fossil-fuel based sources).  Several Proposed Project-area states have Renewable Portfolio Standards (RPS) that mandate power companies to generate a portion of their power from renewable sources: Montana’s RPS is 15 percent by 2015, South Dakota’s RPS is 10 percent by 2015, and Kansas’s RPS is 20 percent by 2020. Nebraska has no RPS.

2.3       BLACK CARBON:

The GHG emissions indicated under “Construction Emissions” and “Operational Omissions” do not include black carbon (soot), which is a climate forcing agent that is a product of incomplete combustion.  Black carbon is a particle rather than a GHG, with a much shorter atmospheric lifespan on the order of 5.3 to 15 days, depending on the meteorological conditions where it is removed from the atmosphere in precipitation or through deposition, compared to the lifespan of CO2, which is on the order of hundreds of years (US Climate Change Science Program 2008, Archer et al. 2009).

The Final Supplemental EIS does not include a discussion of black carbon emissions because the available science and information available suggest that they are a negligible contribution alongside the sources of GHG emissions associated with construction and operation of the Proposed Project. There is no generally accepted method for summarizing and normalizing the different effects that black carbon emissions have on the climate.  This is a result of the high level of uncertainty regarding the total climate effect of black carbon emissions and in expressing black carbon emissions in terms of CO2 equivalence.  The climate forcing from black carbon occurs through numerous mechanisms including changes in albedo.  Albedo refers to the reflectivity of a surface – particularly when deposited on ice surfaces – increasing cloud droplet concentrations and thickening low-level clouds.


This section estimates the incremental lifecycle GHG emissions associated with the Western Canadian Sedimentary Basin (WCSB) crude oils that would be transported by the Proposed Project compared to reference crudes that would likely be displaced. The analysis was undertaken based on a review of existing lifecycle studies and models that estimate GHG emissions and implications for WCSB oil sands-derived crudes in comparison to reference crudes currently being distributed and refined in the United States. The analysis estimated the full lifecycle GHG emissions of the WCSB crude oils and the reference crudes.


The reference crudes were selected as examples of crudes that are likely to be displaced from the US crude oil market and/or the world crude oil market by increases in crude oil produced from the WCSB.  Because crude oil produced in the WCSB generally has higher lifecycle GHG emissions than the potentially displaced reference crude oils, increases in WCSB crude oil in the US (or world) market would increase overall lifecycle GHG emissions of the crude oils consumed.

The emissions associated with production, refining, and end use of the crude oil that would be transported by the proposed Project are assessed as potential indirect or cumulative effects. Indirect effects of an action include those that are caused by an action and occur later in time or farther away in distance but that are still reasonably foreseeable. Indirect effects may include growth-inducing effects. Cumulative effects are those that result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions.

The total capacity of the proposed Project is 830,000 bpd. Of that 830,000 bpd of capacity, up to 100,000 bpd is reserved for production from Montana and North Dakota that would be delivered to the proposed Project in Baker, Montana. The proposed pipeline may also transport conventional crude oils from Alberta, Canada, in addition to oil sands crudes.  Although not all of the capacity of the proposed Project would be used to transport oil sands crude oils, however, the estimates in this section are based on 830,000 bpd of oil sands crudes to present a conservative, high-end estimate of emissions associated with crude oil that could be transported by the proposed Project.

For completeness and comparison purposes, the GHG emissions associated with land use changes attributable to the WCSB crude oil mining, and to a lesser extent in situ extraction methods, have also been calculated, as has the relative importance of how petroleum coke is addressed in the lifecycle analyses.


Here is a reality check.  Canada as a whole represents less than two per cent of global greenhouse gas emissions; the oil sands represent approximately 0.16 per cent of global emissions.  Keystone XL’s impact on GHG’s both globally and in the US amount to little more than a rounding error.  Despite its minimal contribution, Canada recognizes it must continue to be a leader in environmental performance.  Canada has agreed along with the United States to reduce its carbon emissions by 17 per cent below 2005 levels by 2020 as per the Copenhagen Accord.  Looking at Canada’s emissions, and specifically the oil sands industry, the oil sands make up just 7.8 per cent of Canada’s total emissions.  In 2011, oil sands emissions were 55 million tonnes which is equivalent to 4.3 per cent of emissions of US coal sector.  That’s less than the emissions from two coal-fired power plants in the State of Georgia.

The Canadian oil sands are the third largest deposit of oil in the world. They are an incredibly important and strategic resource for North America.  It is absolutely critical to North America and the world that these resources are continued to be developed in an environmentally responsible manner and that is why intensity from oil sands projects have decreased 26 per cent per barrel since 1990.  Canada is the only major oil supplier to the United States that has strict environmental regulations, puts a price on carbon emissions and protects the rights and freedoms of workers.Slide3

In order to understand the impact of 18.7 million tons of CO2, it should be put it in the context of total US Carbon Dioxide (CO2) emissions.   According to the EPA, in 2012 the United States emitted 6.5 billion metric tons of CO2 equivalent.  This means that the annual increase from Keystone would amount to less than three-tenths of one percent of the total annual CO2-e emissions — 0.286546 percent as illustrated in the Figure 4/03.

So, 18.7 million tons sounds like a huge number on its own, but consider that more than 10 times that much CO2-e gets released into the atmosphere each year from methane produced by cows.  In other words, in terms of overall CO2-e emissions, Keystone amounts to a little over one tenth of US cow flatulence.

The Proposed Keystone XL pipeline would have “no material impact” on US GHG emissions, according to a new IHS study which was concluded in August 2013.  In the absence of the pipeline, alternate transportation routes would result in oil sands production growth being more or less unchanged, the study says.  The study also found that any absence of oil sands on the US Gulf Coast (the destination for Keystone XL) would most likely be replaced by imports of heavy crude oil from Venezuela, which has the same carbon footprint as oil sands.

The new IHS CERA Canadian Oil Sands Dialogue study agrees with the conclusions of the US State Department’s DSEIS for Keystone XL that says oil sands production is expected to continue at similar levels regardless of whether Keystone XL goes forward.  IHS currently expects oil sands production to grow from 1.9 million barrels per day (mbd) in 2013 to 4.3 mbd in 2030 and does not expect the Keystone XL decision to have a material impact on the production outlook.  The study points out that 3 mbd of additional oil sands pipeline capacity (not including Keystone XL) is currently proposed.  Eighty percent of this Proposed alternate capacity travels exclusively through Canada—connecting the oil sands with Canada’s west and east coasts—and thus would not require US government approval.

The study also found that, were oil sands not to be shipped to the US Gulf Coast, it would result in little to no change in overall GHG emissions. The region—which contains 50 percent of total US refining—has a large capacity to process heavy crude. This means that crude oils of similar GHG intensity would continue to be refined in the absence of oil sands, the study says.


  1. Environmental Consequences – Greenhouse Gases and Climate Change;
  2. TransCanada – Keystone XL will have minimal impact on GHG;
  3. Washington Post – Keystone emissions amount to a fraction;
  4. Cumulative Effects Assessment and Extraterritorial Concerns;
  5. HIS Study – Keystone XL Pipeline;
  6. Oil & Gas Pipelines Market Report 2014-2024 by Visiongain;
  7. Canadian Pipeline Transportation System by Canadian National Energy Board (2014);
  8. The National Energy Board (NEB);
  9. Historical Pipeline Incident Analysis;
  10. Safety Operations – TransCanada;
  11. The Basics of Safety – TransCanada;
  12. Designed to Last for Decades – TransCanada;
  13. Operating Safety – TransCanada;
  14. Federal Government Announces New Measures to Strengthen Regulations for Pipeline Safety;
  15. Executive Summary – Final Environmental Impact Statement for the Proposed Keystone XL Project; and
  16. Pipeline 101.