Last week the Alberta government responded to the U.S. State Department's final supplemental environmental impact statement (FSEIS) on the Keystone XL project by emphasizing the province's responsibility, transparency, and confidence that the pipeline is in the "national interest" of both Canada and the U.S.

In a statement, Alberta Premier Alison Redford appealed to the relationship between the U.S. and Canada. Premier Redford pointed out that the FSEIS had "recognized the work we're doing to protect the environment," saying that "the approval of Keystone XL will build upon the deep relationship between our countries and enable further progress toward a stronger, cleaner and more stable North American economy."

Environment and Sustainable Resource Development Minister Robin Campbell also issued a statement, mentioning Alberta's "strong regulatory system" and "stringent environmental monitoring, regulation and protection legislation."

Campbell's reminder that the natural resource sector "provides jobs and opportunities for families and communities across the country" was similar to Premier Redford's assurance that "our government is investing in families and communities," with no mention made of corporate interests.

In order to provide a more specific and sciene-based response to the FSEIS report on Keystone XL, Pembina Institute policy analyst Andrew Read provided counterpoints to several of its central claims.

1. Oilsands Emissions

The U.S. State Department's report claims that "Alberta's oil sands account for about 5 per cent of Canada's overall GHG emissions and Canada is responsible for about 2 per cent of global emissions."

Read says that "oilsands are the fastest growing source of emissions in Canada," and industry and government have been unable to curtail rising emissions in contrast to other industrial sectors. Emissions in 2011 from mining and oil and gas extraction were up 450 per cent from 1990 levels, 200 per cent from 2000 levels and 93 per cent from 2005 levels. These rising numbers are "primarily attributable to oilsands expansion and transportaion emissions" according to federal reports, says Read.

The FSEIS mentions the Climate Change and Emissions Management Act, passed in 2003, as establishing mandatory annual GHG intensity reduction targets for large industrial GHG emitters. But these targets have only been around since 2007 with the passing of Specified Gas Emitters Regulation.

2. Carbon Capture and Storage

The report mentions that the Alberta government has devoted $2 billion to fund "four large-scale CCS [Carbon Capture and Storage] projects," with two involving oilsands producers. The Alberta government has actually committed to spending around $1.4 billion to support the two CCS projects involving oilsands upgrading. The projects are only expected to reduce 2.6 million tonnes of CO2 annually, not 15.2 million tonnes, as claimed by the U.S. State Department.

For more on Alberta's failed CCS plans, read DeSmog Canada's two-part series.

3. In Situ Recovery of Bitumen

The FSEIS claims that 80 per cent of oilsands bitumen is recovered through in situ techniques using SAGD (Steam Assisted Gravity Drainage), which is "less disturbing to the land surface than surface mining and does not require tailings ponds."

While 80 per cent of bitumen is too deep to mine, only 50 per cent is currently produced in situ. Furthermore, the FSEIS ignores the downsides of in situ exploration and development, which disrupts ecosystems by creating "fragmentation of habitats" and "pathways for increased predation," and is also land intensive. In situ extraction techniques are also more greenhouse gas intensive than mining techniques, and increased production from those sources will ultimately lead to an increase in GHG emissions.

4. Water Withdrawals

The FSEIS reports that all approved oilsands projects can "withdraw no more than 3 per cent of the average annual flow of the Athabasca River," with 2008 withdrawals coming to 0.8 per cent of the long-term average annual flow.

Read emphasizes that these numbers are misleading because water withdrawals "are not halted when river flows reach extremely low levels that can result in damage to the Athabasca." For example, in winter periods when river flows are much lower withdrawals have been seen to reach 15 per cent of river flow. Read says that "comparing withdrawals to average flows masks the seasonal variability that is observed on the river."

The FSEIS also claims water use by oilsands operations has continued to decrease despite increased production, with many in situ operations recycling up to 90 per cent of water used. But this decrease is only on a "water use per barrel basis," with total water usage increasing due to expanded production. Furthermore, even water recycled during oilsands operations is permanently removed from the ecosystem, along with the 10 per cent additional water required.

5. Air Quality Monitoring

The FSEIS claims that long-term air quality monitoring "since 1995 shows improved or no change in CO, ozone, fine particulate matter, and SO2, and an increasing trend in NO2."

Read notes that over that 10-year period, there has been a lot of fluctuation in the ambient air concentration of these pollutants. Particularly, NO2 and SO2 have been seen to spike during certain periods. However, particulate matter "has been increasing at certain monitoring sites in the oilsands region." The Canadian government is also showing elevated levels of fine particulate matter above their own 2015 target in the "prairies and northern Ontario" region which contain the oilsands developments.

6. Tailings

The FSEIS observes that "processing 1 tonne (1.1 tons) of oilsand produces about 94 liters (25 gallons) of Tailings," to which Read responds that 1.5 barrels of tailings are produced for every barrel of bitumen mined from the oilsands.

The volume of tailings will continue to grow "more than 40 per cent from 830 million cubic metres to more than 1.2 billion cubic metres in 2030," and will continue to grow until stabilizing at 1.3 billion cubic metres around 2060, says Read.

A recent Environment Canada study found toxic chemicals from tailings ponds are leaching into groundwater and the Athabasca River.

7. Land Reclamation

The FSEIS reports that "602 km2 (232 mi2) have been disturbed by oilsands mining activity of which 67 km2 (26 mi2) has been or is in the process of reclamation."

The actual area of land disturbed by oilsands development is 715 square kilometres (71,500 hectares). Out of that, "only 1.04 square kilometres (104 hectares) is certified by the government as reclaimed." The FSEIS's figure is closer to the amount of land unofficially reclaimed (65 square kilometres), but this self-reported claim remains unverified due to "a lack of regulated standards and requirements to reclaim land as further land is disturbed," says Read.

Read puts the estimated cost of reclaiming the disturbed land, based on available government and industry data, at $10-$15 billion, or approximately $220,000 to $320,000 per hectare.

8. Potential Impacts and Environmental Monitoring

The FSEIS states that "Alberta has committed to a cumulative effects approach that looks at potential impacts of all projects within a region," and requires oilsands operations to have plans to "minimize their effects on wildlife and biodiversity." The report also mentions that the Alberta government "monitors and verifies" that these plans are undertaken.

Alberta and Canada have continued to approve projects that have been shown to have "significant and irreversible" adverse environmental effects through the environmental review process. There are also concerns about the enforcement of these rules. Read points to a 2013 report that surveyed 9,000 reported incidents in the oilsands, and found that "less than one percent of likely environmental infractions drew any enforcement."

Images: Kris Krug via flickr

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