The Keystone XL Pipeline: Lessons for EIA Climate Change Considerations

On March 7, 2014 the public comment period for the Keystone XL Pipeline (KXL) Final Supplemental Environmental Impact Statement (FSEIS) closed, bringing forward over 2 million submissions demanding rejection of the project and a protest outside the White House that ended in the arrest of dozens of students. These reactions come as a result of concerns to human health and environmental degradation.  An added consideration is whether the project meets Obama’s criterion that it not undermine Washington’s efforts to fight climate change [1].


Several hundred students gather outside of the White House to protest the Keystone XL Pipeline on March 2, 2014.

As an energy project that crosses national borders, the developers must submit an EIS and obtain a Presidential Permit [2]. Under executive order 13337, a Presidential Permit is issued if “issuance of a permit would serve the national interest” [2]. In June 2013, Obama qualified ‘national interest’ in a new way when he declared: “Our national interest would be served only if this project does not significantly exacerbate the problem of carbon pollution” [3].

The FSEIS released in January 2014 addresses carbon emissions in Volume 3, Chapter 4.14: Greenhouse Gases and Climate Change. However, recent reports published by environmental organizations, such as the NRDC and Carbon Tracker, fundamentally question the validity of the statements made in this section of the FSEIS. Through the use of a number of questionable assumptions in their models, the FSEIS underestimates the effect the pipeline will have in undermining emissions reductions commitments. A particularly striking way that the assessment miscalculates is in the baseline data it uses as comparison. The model compares a future with the KXL to a ‘business as usual’ future – i.e. a future where efforts are not made to reduce emissions, and therefore one that does not significantly diverge from the KXL future. By contrast, when the project is compared to the target path for emissions reductions, it is clear that development of the pipeline is incompatible with US climate objectives (Figure 1) [3].

Figure 1. Graph depicting the difference between the ‘business-as-usual’ model used as a baseline comparison for a future with the Keystone XL Pipeline, versus the United States’ ‘target path.’

A second controversial finding is that “…approval or denial of any one crude oil transport project, including the proposed Project, is unlikely to significantly impact the rate of extraction in the oil sands” [4, p4.14-5]. Research by the NRDC and Carbon Tracker [5] indicate that these findings are inaccurate. Where the FSEIS assumes high oil prices and a flourishing tar sand industry, the NRDC finds a high likelihood of low oil prices within the next decade and the existence of current ‘bottlenecks’ constraining tar sands expansion [3]. This means that if approved, the KXL would be a direct driving force in the maintenance and growth of the carbon intensive tar sands industry.

A decision to approve the KXL despite its clear incongruity with environmental commitments, and the blatant failure to properly address the effects of the project on greenhouse gas emissions, will send a clear message to future project proponents regarding the level of rigour expected when including climate change considerations within the EIA decision-making process. We can only hope that an environmentally conscious precedent is set.



[1] Daly, M. 2013, June 25. “Obama links Keystone approval to carbon emissions.” Associated Press. Retrieved from:

[2] Exec. Order No. 13337, Issuance of Permits With Respect to Certain Energy-Related Facilities and Land Transportation Crossings on the International Boundaries of the United States, 69 C.F.R. 25299 (May 5, 2004).

[3] NRDC. 2014, March 6. “NRDC Comment on Proposed XL Tar Sands Pipeline Final Supplemental Environmental Impact Statement.” Retrieved from:

[4] United States Department of State Bureau of Oceans and International Environmental and Scientific Affairs. 2014, January. Final Supplemental Environmental Impact Statement for the Keystone XL Project. Retrieved from:

[5] Carbon Tracker Initiative. 2014, March 3. “Keystone XL Pipeline (KXL): The “Significance” Trap. Retrieved from:


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