Keystone: What and How to Count?

EPA's comments on the KXL Final SEIS show that "additionality" has become a real drag on NEPA deliberations.

EPA’s final comments on the KXL Final SEIS made something of a splash today with a piece in today’s New York Times.  They mostly reflect what EPA has been saying about KXL for going on two years now.  As EPA says in its latest filing on the Department of State’s impact analysis,

[t]he Final SEIS states that lifecycle [GHG] emissions from development and use of oil sands crude is about 17% greater than emissions from average crude oil refined in the United States on a wells-to-wheels basis. The Final SEIS also finds that the incremental [GHG] emissions from the extraction, transport, refining and use of the 830,000 barrels per day of oils sands crude that could be transported by the proposed Project at full capacity would result in an additional I .3 to 27.4 million metric tons of carbon dioxide equivalents (MMTCO2-e) per year compared to the reference crudes.

EPA then tried to put these numbers into plainer English:

[t]o put that in perspective, 27.4 MMTCO2-e per year is equivalent to the annual greenhouse gas emissions from 5.7 million passenger vehicles or 7.8 coal fired power plants. Over the 50-year lifetime of the pipeline, this could translate into releasing as much as 1.37 billion more tons of [GHGs] into the atmosphere.

This is much of the divide—the canyon—between the pipeline’s opponents and its proponents.  EPA’s figures rest on certain assumptions about how things will go if KXL is never built.  Those assumptions might be wrong.  So how to count the pipeline’s likely/probable/expected GHG footprint?  Our September 2014 post delves into it in more depth.  Even the Daily Show recently jumped into this canyon to suggest that it shouldn’t exist.

But consider: will it just be the difference between crude-by-rail (like we have now) and KXL?  What if crude-by-rail continues to expand?  What if it contracts significantly? (See our posts on the Department of Transportation’s proposal to significantly improve crude-by-rail’s safety.)  Will it be something very different from any of that because of oil’s massive price volatility?additionality

“Additionality” in GHG accounting has this maddening structure to it no matter what the project or analysis.  We should at least have identified this analytical dilemma by now and have agreed upon some standardized, best-practice-type analytical methods with which to tackle it.  Unfortunately, NEPA still lacks as much.  And that has been a bad thing for the KXL debate.


{Image: Alex Cornell’s inverted iceberg from Antarctica}

I teach environmental, natural resources, and administrative law at Penn State Law. Before teaching I was an enforcement lawyer at U.S. EPA. Along the way I've done work for environmental nonprofits and written a fair bit about NEPA.
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