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Bold Joins Letter to State Department

The State Department is currently seeking comment on what is called the “scoping” phase of TransCanada’s permit application.

The State Department is looking for input on what should be considered and looked at during this environmental review. They have not yet hired a contractor to lead the review process, but very similar to what the Nebraska Public Service Commission did when they asked for citizen input on their “rules and regulation” phase, the State Department is wanting your feedback now as well.

Read more about the State Department process: http://www.keystonepipeline-xl.state.gov

Give input to the State Department on the “scoping” process, send emails to: keystonecomments@state.gov

Letter from national and Nebraska groups, sent July 3, 2012 to the State Department:

Assistant Secretary Kerri-Ann Jones

Bureau of Oceans and International Environmental and Scientific Affairs
U.S. Department of State

2201 C St., NW, Rm 3880

Washington, DC 20520

Re: Comment period extension and suggested analysis for scoping process on environmental impact statement for Keystone XL pipeline

Dear Secretary Jones:

We are writing to formally request an extension of the proposed comment period for the scoping for the new Supplemental Environmental Impact Statement (SEIS) on the Keystone XL pipeline project from 45 to 75 days. A longer public comment period is critical to allow the public, including landowners and others along the proposed route of the pipeline, to provide meaningful input regarding this highly controversial project.

The Keystone XL pipeline will have significant environmental impacts, and is of great interest to our millions of members and supporters. While we understand that a final Environmental Impact Statement was issued in August of 2011 for the first project application for the Keystone XL pipeline and that the Department has proposed to issue a supplement to the final EIS, several factors warrant a wholly new environmental review for this project application.

First, this is a new project. This project not only follows a different route, but will now terminate in Cushing, Oklahoma rather than Port Arthur, Texas. The purpose and need for this project must be carefully analyzed in light of these major changes. Also, there were several major anticipated impacts of this project left insufficiently analyzed in the final EIS of August 2011. We submitted comments outlining concerns and deficiencies on the Draft Environmental Impact Statement (DEIS) on July 2, 2010; and on the Supplemental Draft Environmental Impact Statement (SDEIS) on June 6, 2011. The concerns listed in those two comment letters have were not remedied in the FEIS and remain valid.

This new review process offers a renewed opportunity to properly assess the impacts of the Keystone XL pipeline. The issues requiring additional analysis include: a thorough assessment of a no action option, including clean energy alternatives; an analysis of lifecycle greenhouse gasses throughout the entire life of the project; an analysis of transboundary impacts associated with tar sands development in Canada; an analysis of newly proposed alternative routes that would avoid the Ogallala Aquifer, Nebraska Sandhills, and other important resources; an analysis of expected spill frequency, severity, and emergency response plans in light of the Keystone I spills and the recent Corrective Action Order issued on that pipeline, as well as the line 6B rupture that has devastated the Kalamazoo River and surrounding communities in Michigan; an analysis of the project’s effect on US petroleum markets; an analysis of the connected Bakken and Cushing Marketlink projects; an analysis of environmental justice issues; an analysis of impacts on tribes; and an analysis of the project’s impacts to water resources and sensitive wildlife species.

A comment period of 75 days will enable our members to ensure that these issues are properly identified to the Department particularly given the substantial public controversy over the adequacy of the final EIS.

Given the national controversy over this pipeline, the complexity of the issues surrounding tar sands and the permitting process for this pipeline, the extent to which additional analysis is needed, and the significantly increased interest in this project and its potential impacts, a 75-day comment period is warranted. It is necessary that all stakeholders with an interest in this pipeline and its energy and environmental implications be given sufficient time to provide comment on what should be included in this future review.

Please consider our request for comment period extension so that all concerned parties in this process are given adequate opportunity to comment on what should be included in the scope of this important review.

Thank you, we look forward to continuing to work with you throughout this process.

Sincerely,

Kate Colarulli,
Associate Director, Beyond Oil Campaign, Sierra Club

Danielle Droitsch,
Senior Attorney, Canada Project Director, International Program Natural Resources Defense Council

Jim Murphy,
Wetlands and Water Resources Counsel, National Wildlife Federation

Tiernan Sittenfeld,
Senior Vice President, Government Affairs, League of Conservation Voters

Marcie Keever,
Legal Program Director, Friends of the Earth

May Boeve, Executive Director, 350.org

Jane Kleeb, Executive Director, Bold Nebraska

Joe Uehlein,
Executive Director,
Labor Network for Sustainability

Tyson Slocum,
Director, Energy Program, Public Citizen

Ted Glick,
Policy Director
Chesapeake, Climate Action Network

David Turnbull, Campaigns Director,
Oil Change International

Noah Greenwald M.S.,
Endangered Species Program Director, Center for Biological Diversity

CC:
 Ms. Genevieve Walker Mr. Keith J. Benes 

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208 S. Burlington Ave., Ste 103, Box 325, Hastings, NE 68901