February 24, 2014



United States Department of State
Bureau of Energy Resources, Room 4843
Attn: Keystone XL Public Comments
2201 C Street NW
Washington, D.C. 20520

Re: Comments of the Indigenous Environmental Network (“IEN”) and North Coast Rivers Alliance (“NCRA”) on the Final Supplemental Environmental Impact Statement for the Keystone XL Project

Dear Sir or Madam:

Pursuant to the National Environmental Policy Act (“NEPA”), 42 U.S.C. section 4321 et seq., and in accordance with the public notice provided by the United States Department of State(“State Department”), the Indigenous Environmental Network (“IEN”) and the North Coast Rivers Alliance (“NCRA”) (collectively, “Indigenous and Conservation Groups”), submit the following comments on the State Department’s Final Supplemental Environmental Impact Statement (“FSEIS”) for the Keystone XL Project (“Keystone XL” or the “Project”). Indigenous and Conservation Groups submitted comments on the previous Final Environmental Impact Statement on October 9, 2011, and on the Draft Supplemental Environmental Impact Statement (“DSEIS”) on April 22, 2013, which are attached as Exhibits 1 and 5 hereto, respectively. As discussed below, your FSEIS fails to address many of our previous comments.

IEN is a network of Indigenous Peoples from throughout North America who are empowering their Indigenous Nations and communities toward ecologically sustainable livelihoods, long-denied environmental justice and full restoration and protection of the Sacred Fire of their traditions. Its members include chiefs, leaders and members of Indigenous Nations and communities who inhabit the states and province through which Keystone XL is proposed to be built and who would be directly and irreparably harmed by its many severe adverse environmental and cultural impacts. IEN has been involved in grassroots efforts throughout the United States and Canada to mobilize and educate the public regarding the harmful environmental and cultural impacts of Keystone XL. IEN submits these comments to highlight many of the profound deficiencies of the State Department’s FSEIS on this Project, and to enforce compliance by the State Department and all involved federal agencies with NEPA and all applicable environmental and cultural protection laws, treaties, and public trust responsibilities.

NCRA is an unincorporated association of conservation leaders from the western and northern United States and Canada. NCRA has participated in public education, advocacy before legislative and administrative tribunals, and litigation in state and federal court to enforce compliance by state and federal agencies with state and federal environmental laws. NCRA’s members use the land and water resources that the Keystone XL would affect and seek by these comments to protect those resources and ensure that the State Department and other  federal agencies fully comply with NEPA and other applicable environmental laws and public trust responsibilities in their review of the Keystone XL.

On January 31, 2014, the State Department released its FSEIS for the 2012 Presidential Permit application for the proposed Keystone XL pipeline. Its central conclusion is that the Project, which would carry 830,000 barrels of tar sands oil per day from Alberta, Canada to the U.S. Gulf Coast, would not increase the rate of tar sands extraction and would not significantly increase carbon pollution. This conclusion is contrary to common sense and overwhelming record evidence.

Before addressing the many flaws and omissions of the FSEIS, Indigenous and Conservation Groups wish to express their opposition to this Project as an unnecessary perpetuation of the United States’ fossil-fuel centric energy system and its needless and excessive greenhouse gas output at a time when we must drastically curb such emissions or condemn our planet to inexorable, catastrophic climate change. As renowned former NASA climate scientist  James Hansen explains, Keystone XL is the “fuse to the biggest carbon bomb on the planet,” i.e. the tar sands reserves.1 If the Project is approved, Dr. Hansen and many of our best scientists warn that it may be “game over” for the United States’ effort to move from our “addict to oil” to “clean energy.”2

Instead of further tethering the country to oil, the State Department should investigate less harmful alternatives, such as adopting aggressive renewable energy and energy efficiency measures to obviate the claimed need for more crude oil. Yet the FSEIS does not even consider these impact-avoiding and mitigating alternatives. Rather, it restricts its analysis of  alternatives to different ways to utilize the tar sands – some of the most carbon-intensive and greenhouse gas inducing oil reserves on the planet.

The FSEIS’ failure to look beyond the tar sands for renewable energy solutions is analogous to adjusting deck chairs on the Titanic. Unless our nation dramatically alters its present course of increasing dependence on fossil fuels, our planet is headed toward an ecological disaster. The FSEIS should instead provide a robust analysis of renewable energy and energy efficiency alternatives including conservation and small-scale photovoltaic systems such as roof-top solar that are located locally where energy demand is highest (i.e., are “distributed”).

In further expression of this vital concern and others, Indigenous and Conservation Groups offer the following comments on the FSEIS.

The recent ruling3 by Lancaster County, Nebraska Judge Stephanie Stacy invalidating Nebraska Governor Dave Heineman’s approval of the XL Keystone route through Nebraska provides a unique opportunity for the State Department to take a step back and reconsider its inexplicable failure thus far to address the direct impacts of the Project on the natural and cultural environment in Canada, the Project’s irrefutable impacts on climate change, and alternatives that would utilize renewable energy sources such as roof-top solar that would alleviate rather than exacerbate global warming.

Click HERE to read the entirety of the comments – PDF


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