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Letter to Secretary Clinton Speaks Out Against Keystone XL Pipeline
Scott Allegrucci, executive director of The Great Plains Alliance for Clean Energy, speaks out against the proposed TransCanada Keystone XL tar sands pipeline in his public comment to the U.S. Department of State in a letter to Secretary of State Hillary Rodham Clinton.
October 7, 2011
Hon. Secretary of State Hillary Rodham Clinton
United States Department of State
c/o Alexander Yuan
P.O. Box 96503-98500
Washington, D.C. 20090-6503
RE: Keystone XL EIS Project
Dear Madame Secretary:
As the Executive Director of the Great Plains Alliance for Clean Energy (GPACE), I write to you regarding the proposed TransCanada Keystone XL project and the process of administrative assessment related to the National Interest Determination (NID) and Presidential Permit review process for the project.
Briefly, GPACE is a Kansas non-profit organization formed in 2007 to support a clean, secure, prosperous energy economy benefiting Kansas businesses, farms, communities, and all future Kansans. We have coordinated grassroots education and outreach and legislative lobbying with a diverse alliance of partner organizations and communities, including private companies, other non-profit groups, student organizations, and religious congregations around Kansas and the Great Plains region. GPACE has approximately 2,000 active members and a direct, opt-in communications network of over 10,000 citizens.
In addition to our commitment related to current energy policy action, our diverse membership is united by an expectation of ethical conduct in the public interest on the part of our representatives in government, and by a commitment to the well being of future generations of Kansans when enacting policies that will determine their energy and economic realities. If results from multiple statewide, non-partisan polls conducted over the past four years are considered credible, the general views of GPACE reflect those of a majority of Kansas citizens. Of course, I write to you today representing the shared values of our organization and its members.
While we are a regional organization, based in and focused primarily on Kansas, we share the concerns expressed by hundreds of thousands of our fellow citizens around the country regarding the proposed Keystone XL tar sands pipeline project. Those concerns relating to the threat from the project to local communities, precious ecosystems, and critical shared resources (especially fossil and groundwater sources) are in our view legitimate and should in themselves be grounds for at least a revision of the current project EIS, which we consider inadequate.
Added to these concerns are the issues of questionable relationships, influence, and decision-making in the context of governmental ethics and statutory regulations put in place to protect the public interest in just such instances. Without further investigation into and resolution of these legal and ethical issues, we do not see how the Department of State or the President can make a legitimate or binding NID decision regarding the project.
Weighing upon all these credible concerns are significant questions of domestic energy and economic policy, and especially of national and international efforts to address the threats from anthropogenic global climate change. Jobs and economic development assertions in support of the project have been characteristically inflated, in some cases dramatically so, and as such they should not be the basis for credible expectations from or justifications for the project. The ultimate foreign destination of much or most of the refined product of the transported tar sands is a blatant refutation of assertions that the project will meaningfully enhance the national or energy security of the United States. And the direct and devastating contribution to greenhouse gases and subsequent global warming resulting from the extraction and use of dirty tar sands (not to mention the degradation of biomass resulting from mining and pipeline construction and maintenance) completely undermines any commitment or contribution on the part of the United States to prevent or mitigate the significant and unaffordable climate and hydrological disruptions caused by global climate change.
In particular, individual GPACE members (some of whom are landowners and residents living in counties in which the Kansas section of the project is already operational) have expressed the following concerns:
- High pressure, tar sands crude pipelines threaten groundwater supplies in the Ogallala aquifer and shallower groundwater supplies. Sensitive groundwater areas should be avoided and pipeline path changed. Water contamination is an avoidable and many cases irreversible risk from this project – and therefore an inexcusable outcome. TransCanada’s record to date related to pipeline safety and protection of water resources is cause for concern, in addition to the many recent high-profile spills and accidents that indicate widespread planning and compliance problems within the industry.
- In rural areas of pipeline construction, Keystone has been allowed to use thinner wall pipe than in more densely populated areas. Pipe thickness should be uniform and of maximum pressure rating for design pressures to insure safe operation for every environment and community along the pipeline. There have already been leaks detected in rural Kansas sections of the pipeline.
- Pipeline construction should bore under all perennial flow streams and rivers to preserve sensitive riparian areas and maintain bank integrity. Already, residents are seeing erosion and degradation of areas where the pipeline and related construction cross streams.
- Pipeline construction is disruptive to native fish, animal, and plant species, and potential leaks or spills could also devastate agricultural and ranching assets. Pre-construction surveys of fish and animal populations and habitat, as well as agricultural production assets, should have been required with subsequent mitigation plans and post-construction monitoring surveys in place. This has not occurred.
- Pipeline impact on the local economy should be honestly evaluated and reported. “Backroom deals” that result in local property tax giveaways and starve the communities along the pipeline corridor should be disallowed and reversed if in place. In Kansas, Keystone successfully obtained state incentives from the Department of Commerce, and then successfully lobbied state legislative leadership (though not all legislators representing the citizens in communities directly impacted by the project) to obtain long-term incentives in the form of local tax abatements on top of the state incentives. The local tax abatements were accomplished in secret and without any input from or notice to the local governmental entities, and the deals were secured under threat from Keystone that the project would be redirected without such incentives. In particular, the local revenue giveaway to TransCanada/Keystone undercuts assertions of long-term economic benefit from the project.
- Cardno ENTRIX has been working on behalf of the State Department to evaluate Keystone XL since the Bush Administration, and is the company that conducted the State Department’s inadequate environmental review of the Keystone XL pipeline, which was finalized by the State Department a few weeks ago, despite the EPA raising numerous concerns and warning that the review was “insufficient.” Cardno ENTRIX has previously worked on projects for TransCanada, and also worked for BP to conduct the environmental review of the Deepwater Horizon oilrig that exploded in the gulf last year. According to numerous reports, the Cardno ENTRIX representatives running the public hearings have consistently created or contributed to unfair conditions and bias against project opponents and “manufactured” public support for the project. On the heels of a corrupted permitting process for a proposed coal plant in Kansas, and intense pressure and financial expenditures by the out-of-state company that would own that plant and its power, our members are highly suspicious of the influence of special interests on this project, and therefore dubious about its true value to our national interest.
- Documents released recently reveal a cozy relationship between State Department officials and lobbyists for the Canadian pipeline company TransCanada. These documents include emails from a TransCanada lobbyist named Paul Elliot, who previously served as your Deputy Campaign Manager during the 2008 Presidential campaign. State Department officials appear to have coached Elliot and other TransCanada staff about how to build their case for approval, and even how to respond to questions and concerns about pipeline safety and environmental impact. It even appears that Mr. Elliot may have been lobbying illegally—failing to register as a lobbyist for over a year while working on behalf of TransCanada—a potential violation of the Foreign Agents Registration Act. We have had our fill of unethical misconduct by those sworn to fairness in the public interest, and our members are deeply concerned and disheartened by the ongoing apparent disregard for due process and the rule of law that seems to be occurring as part of the Keystone XL project.
As the State Department reviews a Presidential Permit for the Keystone XL pipeline, I ask you to consider the gravity of the risks associated with a pipeline that dramatically threatens our ability to combat climate change. Further expansion of a fuel that releases 17% more carbon pollution than conventional oil will push our climate system past the tipping point and beyond human control.
Keystone XL poses a direct threat to America’s land, air, and water as well as the health and livelihoods of our communities. This pipeline would put at risk sensitive land and water, including the Ogallala aquifer, which provides 30% of our agricultural water and drinking water to 2 million Americans. Allowing TransCanada, a foreign company, to profit from a dirty and dangerous tar sands oil pipeline at the expense of Americans’ drinking water, food supply and economy is not in our national interest.
Our nation has experienced the real impacts of our addiction to fossil fuels, in the multitude of oil spills still affecting communities today, in the rising gas prices across the country, and in the daily threats posed to our troops overseas. Keystone XL would deepen our dependence on oil. Proposed new vehicle fuel economy standards alone will save more than twice the amount of oil the pipeline is projected to deliver. Building the tar sands pipeline would undermine our progress in transitioning America to a clean energy future, send the wrong message to the world, and imperil our children’s future.
As you consider the NID related to the Keystone XL project, on behalf of current and future Kansans, and with respect for the many difficult priorities and objectives you undertake on our behalf, we ask you to consider the impacts of this decision upon our health and well-being, our economic and civic vitality, efforts to protect our natural resources and our economy, and the need for fiscal and environmental responsibility concerning long-term energy investments.
We understand that the current administration must take us in a new direction. Most of us are doing all we can to contribute and succeed in the current moment, but you have a legacy opportunity in this instance to provide our children and grandchildren a better chance to contribute and succeed when their moment comes. We ask you to show bold leadership by denying TransCanada the Presidential Permit. Keystone XL is not in our national interest.
Scott Allegrucci, Executive Director
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