U.S. permits for multiple proposed Canadian tar sands pipelines should be considered in light of an overall climate change strategy, rather than the current practice of considering each energy infrastructure proposal on a project-by-project basis. “The administration’s commitment to aggressive greenhouse gas reduction policies simply cannot be squared with a piecemeal approach to tar sands infrastructure permitting,” say the Sierra Club, Natural Resources Defense Council, Center for Biological Diversity, 350.org, and other groups in an August 11 letter to Secretary of State Kerry. “The Department can only understand the true climate impacts of these pipelines by analyzing their cumulative growth-inducing effect on tar sands development.” But what is the Obama administration’s commitment, really, with respect to fossil fuel development and export?

Full text of the letter to Kerry from environmental groups is here. The letter says, in part:

In comments to the State Department, environmental groups, including many signed on hereto, have provided substantial evidence that Keystone XL will exacerbate carbon pollution and should be denied. But Keystone is not the only tar sands pipeline your Department is reviewing. It is also considering the expansion of the Alberta Clipper tar sands pipeline into the Midwest and may be considering other projects as well, such as Line 3, another line expansion proposal that would service the Midwest. …

The Alberta Clipper Expansion Project would nearly double the capacity of the existing Alberta Clipper pipeline from 450,000 barrels per day (bpd) to 800,000 bpd. An expansion of Line 3 would also expand an existing international pipeline to bring up to 760,000 bpd of tar sands through the Great Lakes region. The tar sands industry has also given strong indications it desires to reverse a cross-border pipeline in New England to bring up to 600,000 bpd of tar sands from Canada to Portland, Maine.

If allowed, these pipelines will spur tar sands expansion. The tar sands industry depends on pipelines to get its product to market. Without them, it is far more likely tar sands will stay in the ground. As the experts writing in Nature urge, decisions on infrastructure projects like Alberta Clipper and Line 3 must be “made in the context of an overarching commitment to limit carbon emissions.” …

The cumulative climate effects of the Alberta Clipper expansion, Keystone XL, and other tar sands infrastructure projects must be evaluated before we are locked into decades of economic and environmental damage. Given the serious climate impacts of enabling tar sands expansion, we believe such an analysis will lead to a conclusion that the Alberta Clipper expansion, Keystone XL and other similar pipelines must be denied.

There are multiple reasons to deny a permit for the Keystone XL pipeline. Most urgently, there is an overriding U.S. national interest in forestalling the development of a huge new fossil fuel source that will exacerbate global climatic disruption and undermine the transformation of the energy system to decarbonized sources. Granting a pipeline permit would expedite the full-scale development of the tar sands and their movement into the global market. This argument takes on even greater urgency in the context of multiple proposed pipelines for getting the tar sands out of Canada, moving them into and through the U.S.

It is likely the State Department substantially underestimated the Keystone XL pipeline’s impact on increasing tar sands oil production, and the resulting growth in greenhouse gas emissions. Statements by oil industry executives and analysts suggest that, without the KXL pipeline, development of the tar sands would be slowed and limited. The considerable pressure exerted on behalf of the pipeline by industry interests and the Canadian government clearly indicate its importance for full-scale tar sands development. It belies the conclusion in the State Department’s Environmental Impact Statement that this question has already been settled and is essentially independent of any decision on the pipeline permit.

A Canadian move toward multiple pipeline options for the tar sands suggests the potential for an even greater volume of prospective tar sands development. It suggests the crucial importance of pipelines for full-scale development — and thereby the opportunity to seriously undercut this development. But only if multiple pipeline options are blocked to the greatest extent possible.

In its environmental review of the Keystone XL proposal, the State Department used business-as-usual energy scenarios that didn’t include any option that would point toward preventing a 2 degrees C increase in average global temperature. Thus, the unstated assumption of the review was that the nations of the world will not implement policies needed to avoid potentially disastrous climate change.

What would be the implication of allowing, or not allowing, tar sands pipelines if the U.S. (and Canada should be included here, if Canada were serious about climate change) was committed to keeping as much as 80 percent of current fossil fuel reserves in the ground? It is difficult to see how developing, transporting, and refining the tar sands would be anywhere near the most economical (let alone environmentally acceptable) option for burning a strictly limited quantity of fossil fuel while expediting a phase-out.

But that isn’t how the U.S. approaches the problem of environmental impacts assessments and permits for proposed energy infrastructure projects. Instead, federal agencies review proposed projects on a case-by-case basis. They use tools like cost-benefit analysis and estimates of the Social Cost of Carbon. For some traditional purposes, this approach could be sufficient, though lacking an overall development strategy. But in the case of climate change, where projects’ emissions of greenhouse gases are cumulative and long-lived, with potentially widespread and severe impacts of global consequence, it is no longer appropriate.

The case-by-case procedures used now for estimating the benefits of reducing emissions, and the Social Cost of Carbon metric in particular, fall far short of including the full range of expected damages from global climatic disruption. Project-by-project decisions on U.S. government permits for energy infrastructure creates a bias in favor of approving fossil fuel development.

Considering the cumulative impacts of multiple proposed tar sands pipeline projects, as called for in the letter to Kerry, would be a notable step in the right direction. And the same reasoning might be applied to the problem of multiple proposed coal export terminals in the Pacific Northwest, and multiple coal leases on federal land in the Powder River Basin.

The White House and federal agencies should be pushed to come up with an alternative, risk-management approach to incorporating the threat of global climate disruption into decisionmaking on policy, regulatory impact analysis and rulemaking, environment impact statements and permitting.

But what, exactly, is the administration’s approach to tar sands development and export? In the February 13 issue of Rolling Stone (“How the U.S. Exports Global Warming — While Obama talks of putting America on the path to a clean, green future, we’re flooding world markets with cheap, high carbon fuels”), Tim Dickinson calls out the administration for pushing tar sands oil as a ‘free trade’ issue:

“The tar-sands boom has the United States poised to become a top player in the global-export market for gasoline and diesel. And Obama’s top trade ambassador has been working behind the scenes to make sure that our climate-conscious European allies don’t shutter their markets to fuels refined from the filthy Canadian crude. …

“In backroom negotiations, [U.S. trade representative Michael] Froman has worked to undermine new European Union fuel standards intended to lower the continent’s carbon emissions. The European standards would work, in part, by grading the carbon toxicity of various crude oils. They logically propose placing polluting tar-sands oil in a carbon class all by itself; on its path from a pit mine to the filling station, a gallon of tar-sands gas is responsible for 81 percent more climate pollution than the average gallon of regular. But instead of respecting the EU’s commitment to slow global warming, Froman has worked to force North America’s dirtiest petrol into the tanks of Europe’s Volkswagens, Peugeots and lorries.

“[Froman] turned the standards into a point of contention in negotiations of the Transatlantic Trade and Investment Partnership – a major free-trade pact being hammered out between the U.S. and the EU. Last October, Froman’s team even went before the World Trade Organization to demand that all globally traded petroleum products be treated ‘without discrimination.'”

So, calling on Kerry to evaluate multiple pipeline permits on a cumulative basis is calling for a step in the right direction — but what constraints is Kerry operating under with regard to the administration’s political relationship with the fossil fuel interests?

Earlier posts:

New study suggests Keystone XL emissions could be 4 times higher than State Dept estimate (August 11)

What to do about the “Social Cost of Carbon” metric? — Part 1 (July 23)

What to do about the “Social Cost of Carbon” metric? — Part 2 (July 25)

Deep Decarbonization: Truly facing the climate challenge (July 22)

100+ scientists and economists call on Obama and Kerry to reject Keystone XL (April 8)

More on why Keystone XL is not in the national or global interest (March 16)

Comment to State Department on Keystone XL pipeline “National Interest Determination” (March 6)

On Keystone XL, John Kerry, and the global interest (February 17)