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Joanne Pan

GES328

Dr. Lansing

May 18, 2016

Balancing the Economy and the Environment: The Keystone Pipeline

Introduction

In 2010, TransCanada applied for a permit through the US State Department to build the

Keystone Pipeline XL. In late 2015, President Obama vetoed the Keystone Pipeline, a pipeline

that stretched from the boreal forests of Alberta, Canada to the oil refineries of Texas, and would

cut through six states in areas vulnerable to ecological damage. The pipeline was an international

issue because it would go through both Canada and the United States, and was about the future

of energy in America and in international markets. In a statement from his Press Secretary,

President Obama justified his veto by arguing that the points the proponents made weren’t

enough to justify him allowing the pipeline to be built, arguing

…Let me briefly comment on some of the reasons why the State Department rejected this

pipeline. First: The pipeline would not make a meaningful long-term contribution to our

economy…Second: The pipeline would not lower gas prices for American consumers…

Third: Shipping dirtier crude oil into our country would not increase America’s energy

security. What has increased America’s energy security is our strategy over the past

several years to reduce our reliance on dirty fossil fuels from unstable parts of the world.

(Obama, 2015).

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The United States has historically been dependent on dirty energy and fossil fuels, which

President Obama wants to ease the United States off of. The proposition TransCanada had for the

Canadian government and the American government was to build a pipeline that would link

together the boreal forests of Canada, with its supply of tar sands, to refineries along the Texas

coast and ship it out. Both countries would benefit because Canada has access to a larger market

and the United States gets oil from a stable part of the world.

However, the controversy over the pipeline would gather together an unlikely alliance of

environmentalists, labor unions, First Nation communities in Canada, environmental groups such

as the Natural Resources Defense Council (NRDC), Sierra Club, and the National Wildlife

Federation (NWF), scientists, and Canadian environmental groups such as the Pembina Institute,

Environmental Defence Canada, and Greenpeace Canada. The rhetoric of protesters and energy

companies shifted governmental action and policy to see how the United States government will

approach future energy projects both domestically and internationally, and how much say

governments, big energy companies and producers have in the energy markets.

Background

In 2010, Canadian energy company TransCanada applied for a permit to build a “1,664-

mile project that would transport 830,000 barrels of crude oil a day, most of it from Canada’s oil

sands to refineries in Port Arthur, Tex.” (Eilperin, 2014), and would “cross environmentally

sensitive and agriculturally important areas, including Nebraska’s Sandhills and the Ogallala

Aquifer” (Killing KXL, 2015). However, transportation of tar sands can be devastating, as the

2010 Kalamazoo oil spill in Michigan can testify. According to the National Wildlife Federation,

the Kalamazoo, Michigan was built by Canadian company Enbridge, TransCanada’s largest

competitor who

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…was responsible for the largest and costliest inland oil spill in U.S. history, when a

pipeline rupture sending over a million gallons of tar sands into the Kalamazoo River

system poisoning people and wildlife for miles around. This disaster underscored the

weakness of our state and federal safety regulations, but also showed how unprepared the

industry is to respond to a toxic spill: almost three years later the river remains polluted

despite Enbridge spending nearly $1 billion on the cleanup. (Growth of Tar Sands Across

the Midwest, National Wildlife Federation).

Proponents of the pipeline included TransCanada, the Canadian government and oil

companies, argue that the pipeline would bring jobs and help revitalize the economies of the

states the pipeline ran through, and “improve U.S. energy security and decrease reliance on

Middle Eastern oil” (Song, 2011) while opponents include the domestic and international

environmental groups such as Greenpeace Canada, Natural Resources Defense Council and the

National Wildlife Federation, ranchers and farmers, and landowners who claim that “it will make

it harder for the U.S. to shift away from fossil fuels, and will expand production in Canada’s oil

sands” (Eilperin, 2014). Both sides have equally valid arguments, and have taken the issue to

court.

During his first term in office, President Obama wanted a comprehensive and thorough

review of the pipeline from his State Department, because as an international issue it fell under

their jurisdiction. Other actors in the issue include TransCanada, the Canadian and US

government, the North American Free Trade Agreement (NAFTA), and eight federal agencies,

which include the State Department, the Environmental Protection Agency, the Department of

the Interior and Department of Commerce, oil companies, labor unions, and First Nation

communities in Canada and Native American tribes in the United States. The pipeline sets

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economic interests against environmental preservation, where the environmental groups want to

save the area and keep it as pristine as possible.

TransCanada claims that there have been five studies, 17,000 pages of scientific analysis,

and a seven year review process and should not have been denied. Legislation for and against the

pipeline was fierce, and in January 2016, TransCanada filed a lawsuit under NAFTA, claiming

that while creating the pipeline may have repercussions on the environment, the economic gains

it would bring would offset that because of all the jobs that would be created. They also claimed

that “Misplaced symbolism was chosen over merit and science-rhetoric won out over reason”

and as a result, filed a lawsuit under NAFTA, and will apply for another permit sometime in the

future. The controversy was summed up by White House Press Secretary Josh Earnest who said

“I would venture to say that there’s probably no infrastructure project in the history of the United

States that’s been as politicized as this one” (TransCanada, 2015).

TransCanada had spent over seven years waiting for the permit to be approved, and

touting the economic benefits, and repeating what proponents of the pipeline had been telling

Congress. According to their website

This pipeline was intended to be a critical infrastructure project for the energy security of

the United States and for strengthening the American economy. The pipeline would have

meant thousands of much-needed jobs for Americans, increased tax benefits for counties

and communities, and a safe, secure, reliable source of energy to help fuel the everyday

lives of Americans. On November 6, 2015, President Obama denied the required

presidential permit for the Keystone XL Pipeline. (TransCanada, 2016).

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Their rhetoric compelled both Republican and Democratic senators in Congress to help

push the pipeline through. However, in the 113th Congress Senate bill 2280, sponsored by

Senator John Hoever (R-ND) was killed in the Senate by a vote of 59-41, with 45 Republican

Senators and 14 Democratic Senators voting yes, and 39 Democratic Senators and two

Independent Senators voting no. (“Senate Vote 280-Defeats Keystone XL Pipeline.” 2016). The

bill then fell to President Obama in a last-minute effort to push through, and after reviewing all

the documents from the State Department and from other governmental agencies, vetoed it.

President Obama had to balance economic interests against the environment, and with a

presidential election coming up there wasn’t much he could do about it, because approving the

pipeline would “infuriate environmentalists, who not only lent major support to Democrats in the

recent election but will serve as important allies in legislative battles as well as the 2016

presidential race” (Eilperin and Mufson, 2014).

Environmental groups had been trying to persuade the communities and other grassroots

organizations to look at the environmental damage that would be done. In Nebraska, where the

pipeline would affect the Sands Hills landscape and the Ogallala Aquifer, a court decision

invalidated “Keystone XL’s route through Nebraska has reverberations that extend far beyond

the borders of that state and is likely to have a major impact on the federal evaluation process”

(Swift, 2014). Nebraska’s district court decision also showed that the “Citizens v Pipeline case is

a huge win for both the citizens of Nebraska as well as the larger global community that would

be subject to the climate impacts from an expanded tar sands industry” (Swift, 2014) despite both

Republican senators voting yes for the bill to be pushed through.

As of January 2016, TransCanada has filed a lawsuit under NAFTA, and will sue the

United States government claiming that they

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…[H]ad every reason to expect its application would be granted, as the application met

the same criteria the U.S. State Department applied when approving applications to

construct similar cross-border pipelines-including the existing Keystone Pipeline, which

has safely transported more than 1.1 billion barrels of Canadian and American oil through

Canada and the United States. (TransCanada, 2015).

There has been no response from either NAFTA or the United States yet, but it will still

be a political controversy for future Congress sessions and Presidents. However, in early January

Time magazine has said that the lawsuit wouldn’t “take place under U.S. law, nor unfold in U.S.

courts” (Edwards, 2016) but would instead fall under the “Investor-State Dispute Settlement”

jurisdiction, which

…allows foreign investors to challenge sovereign nations’ laws and regulations that they

believe violate the terms of a treaty. Those legal challenges are not considered under U.S.

laws, nor by U.S. judges or juries, but through a special arbitration process that takes

place outside of any nation’s court system. (Edwards, 2016).

Time Politics goes on to explain that the “ISDS has been around for nearly fifty years and

resulted in only eighteen challenges to the U.S., and the U.S. has never lost a challenge. (It has

won 13; five are pending)” (Edwards, 2016). Canadian news outlet CBC News Calgary asked

legal experts about the case, and according to Cyndee Cherniak of LexSage, the “odds are

historically against TransCanada, as the U.S. has a 100 per cent winning percentage in NAFTA

claims” but warns “there could be a first” (CBC News Calgary, 2016).

Native American tribes were another major group that was also affected because it would

go across their land. Public Radio International reports that Native Americans tribes involved

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include the “Dene and Creek Nations to the Omaha, Ho-chunk and Panka tribes” (Boos, 2015).

Opponents of the pipeline argue that many of the Senators who are expected to vote yes for the

pipeline are fueled by big oil companies, and tribes agree, saying that “a lot of tribes are really

frustrated at the lack of inclusion in the process that’s guaranteed through our treaty rights” and

that “the State Department’s permitting process has overlooked tribal treaties with the federal

government” (Boos, 2015). The clash between conservative Republicans and environmentalists

is shown when the Senate voted to pass the bill or not, and all Republicans voted yes and the

majority of Democrats voted no. In a statement, Senator Bernie Sanders (I-Vt.) said “This veto

tells the world that our nation takes seriously the planetary crisis of global warming and that we

will not support legislation that would let a Canadian oil company ship some of the dirtiest oil on

the planet across the United States” (Eilperin and Zezima, 2015).

The Case

The pipeline has become a controversial issue because both sides have valid arguments,

both Canada and the US are part of NAFTA, and what could happen to the climate are issues that

President Obama and his administration must take into consideration.

The Washington Post explains that there are two reasons it has become similar to the

Alaskan drilling controversy in the 1980s, and scientific evidence to prove that it would undo the

promise 196 countries made in the 2015 Paris Treaty. Washington Post journalist Juliet Eilperin

explained that

Extracting bitumen…from the region is more akin to mining than conventional oil

drilling, and the process of extracting crude or bitumen from oil sands emits roughly 15

percent more greenhouse gas emissions than the production of the average barrel of crude

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oil used in the United States…The pipeline also crosses a half dozen states, and the

people living along the route are concerned that spills from the pipeline could damage

ecologically-sensitive habitat. While the project’s sponsor TransCanada says this new

pipeline will boast the newest technology…recent spills like last year’s breach of the

Exxon pipeline in Mayflower, AR has may people worried. (Eilperin, 2014).

In order to turn the tar sands into a form of usable energy, it requires a lot of money and

water, and the outcomes are high pollution levels, heat, and decimated forests. Scientific

American journalist David Biello explained that

Bitumen…requires roughly 12 barrels of water to separate one barrel of it from the sand,

although only three of those barrels are consumed, thanks to recycling. That water also

has ot be hot to separate the clingy hydrocarbon-at least 50 degrees Celsius, which

requires burning natural gas to heat it…it is chemically manipulated further with heat and

pressure in a process known as “upgrading”…that’s just for the tar sands close enough to

the surface-no more than 80 meters deep-to be mined. For deeper deposits, volumes of

superhot pressurized steam are pumped underground to melt out the bitumen so it can be

sucked up to the surface by production wells running in parallel. Such…production

requires less water but far more energy to get the bitumen flowing, resulting in

greenhouse gas emissions some 2.5 times higher than those from mining (Biello, 2016).

TransCanada and its proponents touted the benefits of the pipeline, saying that hundreds

of thousands of new jobs would be created, would be an economic boon and everyone would

share in the money the bitumen would bring. However, opponents say that this ignores the real

issues of how much carbon dioxide and heat is released into the atmosphere from transforming

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the bitumen into usable energy. In one study done by the United States Environmental Protection

Agency, they found that

The…Keystone XL tar sands oil would result in additional greenhouse gas emissions of

27 million metric tons annually compared with conventional oil. Regardless, the tar sands

represent a significant chunk of potential carbon emissions, and those from tar sands have

increased in recent years—up 16 percent since 2009, according to CAPP. Keystone XL

itself would exacerbate that—the U.S. State Department notes that the greenhouse gas

emissions from just the pipeline's pumps would be 4.4 million metric tons per year,

roughly the same as one average U.S. coal-fired power plant (Biello, 2016).

The Montana chapter of the Sierra Club explained how potentially disruptive and

devastating the extraction would be. According to Bob Clark, “Extracting tar sands is one of the

most destructive projects on earth. Reliance on tar sands oil hinders our ability to avoid climate

disaster”, and because “it’s the dirtiest oil on earth with 11 times more sulfur and nickel and 5

times more lead than conventional oil, emits nearly twice the greenhouse gases, and would

exacerbate climate change.” (Clark, 2016).

The pipeline was about the short-term economic impact and boon it would bring to

agricultural communities for the State Department, the state government and local leaders, rather

than the long term issues. Citizens opposing the pipeline argue that it would affect them the most

because it was their land and water that would be polluted if the pipeline went through.

Opponents were looking at the long-term rather than the short term, and found that global

warming would be quicker than ever before. Leading climate scientist James Hansen from

NASA warned that “the tar sands were ‘one of our planet’s greatest threats’” (Killing KXL,

2015).

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Scientific American concurred with other environmental groups and explained that not

only would the climate suffer but repercussions would be felt for generations. In December 2015,

196 countries came together to agree on a treaty that would decrease the amount of greenhouse

gases, which would allow the United States to reach their goal of “reducing global warming

pollution” (National Wildlife Federation, Keystone XL Pipeline). Although the bill didn’t pass

the Senate, if it had been passed it would be ‘game over’ for the climate, says NASA climate

scientist James Hansen. Scientific American backed him up, saying that the pipeline would

“move enough tar sands oil to result in another 181 million metric tons of greenhouse gases

entering the atmosphere yearly” (Biello, 2013). Although Secretary Clinton had implied that she

wanted to move the pipeline through, the decision ultimately fell to President Obama, who,

according to his aides, wanted to see state decisions before making their own, especially the

states affected. Nebraska’s District Court ruled that the governor had no constitutional power to

allow the pipeline being built because it cut through environmentally sensitive land. Federal

agencies added credence to what environmental activists and their allies had been saying. The

EPA “estimated that Keystone XL tar sands oil would result in additional greenhouse gas

emissions of 27 million metric tons annually compared with conventional oil” (Biello, 2013).

Transportation of the tar sands was also an issues for environmentalists and their allies.

Natural Resources Defense Council anti-tar sands advocate Elizabeth Shope argued that “Other

options like rail or truck are not feasibly for the transportation of large quantities” which could

triple “the cost of moving tar sands oil” (Biello, 2013). An LA Times article found that

…the rail system doesn’t have the capacity for the 830,000 barrels of oil the pipeline is

expected to carry each day. Trucks are even slower. In 2013, the United States shipped

about 8.3 billion barrels of crude oil, according to the An. Of Oil Pipelines. Trains carried

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only about 291 million barrels of oil that year, according to the Assn. of American

Railroads (Lee, 2015).

Fracking is becoming a method that isn’t as extreme as turning tar sands into oil, and

opponents claim that fracking would be more beneficial, especially hydraulic fracking. Scientific

American defines fracking as “A single fracture of deep shale” with “action that might be

benign” (Scientific American, 2011). According to the American Water Works Association, the

“use of modern, high-volume hydraulic fracturing techniques to enhance production has

increased dramatically in the United States” since 2000. Although both state and federal

governments have attempted to regulate the use of hydraulic fracking, it claims that there isn’t

enough being done. Hertzler argues that “The earliest regulation by states of the oil and gas

industry also focused on oil conservation measures rather than on protection of groundwater and

surface water” (Hertzler, 2014). Although hydraulic fracking produces large amounts of

wastewater, it can be treated through “underground injection, reuse, on-site treatment, and

treatment at publicly owned treatment works or centralized waste facilities” (Hertzler, 2014).

The pipeline however, would destroy the land it runs through and benefit TransCanada.

Fracking causes another set of problems as well, which include new, untested technology,

high costs, land scarring, water contamination and no scientific evidence for regulations so it

depends on a state by state scale. Scientific American wrote that “Some regulators are not

waiting for better science; they are moving toward allowing fracking on an even wider scale”

(Scientific American, 2011). Public health is another problem for fracking and extraction of

natural gas. According to the American Journal of Public Health, chemicals found in fracking

technology can “damage the lungs, liver, kidneys, blood, and brain.” (Finkel, Madelon L., Law,

Adam. 2010).

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The Environmental Science and Technology journal, part of the American Chemical

Society, argues that fracking would not only destroy land but also get into the water systems of

the states it runs through. Professor Spalding at the University of Nebraska-Lincoln explains that,

“…pipeline construction would disturb fragile Sandhills’ soils and that crude oil releases during

pipeline operation could contaminate large volumes of the Ogallala aquifer. These issues

affected about 225 miles of the route through Nebraska” (Spalding, Roy. 2012). The National

Wildlife Federation compares the pipeline to the “million-gallon Enbridge oil spill in Michigan”

which would negatively affect “America’s agricultural heartland, the Missouri, Platte, and

Niobrara Rivers, the Ogallala Aquifer, habitat for sage grouse and sandhill cranes, walleye

fisheries…Our public water supplies, croplands, and recreational opportunities will all be at risk”

(“Keystone XL Pipeline.” National Wildlife Federation). For environmental activists, the

pipeline was not worth the risk to the environment, especially because it would cause prices in

food to go up and take generations to repair ecologically-sensitive lands. For proponents, the

pipeline is worth the risk to lessen dependency on foreign oil, and would have closer trading ties

with Canada under NAFTA.

Outcomes

Although not unexpected, President Obama had indicated that he would veto the pipeline.

During his administration, he had kept a centrist view on the issue, and in a State of the Union

address said “Let’s set our sights higher than a single oil pipeline” (Liptak, 2015). The White

House Press Office added a statement in late 2015, saying that “The United States will continue

to rely on oil and gas as we transition-as we must transition-to a clean energy economy” (Obama,

2015). He also acknowledged the fact that climate change is a very serious threat and it’s

America’s duty to “fight climate change” (Obama, 2015).

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The pipeline controversy became a rallying point for environmentalists and their allies

because it would affect everyone, whether economically or environmentally. However,

Republicans in Congress did not agree with President Obama’s veto. CNN reports that in a USA

Today op-ed, House Speaker John Boehner and Senate Majority Leader Mitch McConnell wrote

“This White House refuses to listen and look for common ground. It’s the same kind of top-

down, tone-deaf leadership we’ve come to expect and we were elected to stop” (Liptuk, 2015).

Another factor in the outcome were the pictures of pipelines already built and used. The

NRDC wrote in Killing KXL that “images of Canada’s lush green boreal forest and what

happened once the industry dug in-a lunar landscape of mines that stretched one to two miles

across, surrounded by enormous mounds of sulfur and pet coke from refineries” (Killing KXL,

2015) helped activists show the devastation in a formerly pristine habitat to skeptics. Other

activists include Native American communities, who claim that the government did not honor

their treaties with the tribes. The EPA warned President Obama that the “State’s assessment was

‘inadequate.’ It recommended reviewing a broader range of environmental issues, including the

potential impacts of a major spill” (Killing KXL, 2015). President Obama had wanted to “cement

his environmental legacy by forging a climate deal with China, imposing carbon limits on U.S.

power plants” (Eilperin and Mufson, 2014).

Conclusions

After the pipeline was proposed, it became a rallying point for environmentalists and

their allies, especially after the Enbridge oil spill in the Kalamazoo River spilled “nearly one

million gallons of tar sands oil into the Kalamazoo River” in Michigan. The spill resulted in

health problems and “the Enbridge pipeline looked as if a bomb had exploded inside it” (Killing

KXL, 2015).

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Currently, we use some of the most destructive methods known to us allow us to dig

deeper and deeper for fossil fuels, so it costs more to extract it and not enough in renewable

energy. Although the 2015 Paris Treaty had about 196 countries agree to limit their carbon

footprint, they need to find energy sources that won’t cause as much damage and try to slow

global warming and climate change.

The pipeline was also a clash of ideologies, with Republicans in denial about the truth of

climate change. Major media outlets such as The Washington Post, CNN and New York Times

all argue that this was more a fight between conservatives and environmentalists, and more

broadly, a “symbol of the partisan political clash over energy, climate change and the economy”

(Shear and Davenport, 2015).

In the last year of his presidency, President Obama has signed the Paris Treaty along with

196 other nations to curtail the rapid expansion of greenhouse gases. Currently, there is no

timeline to see if TransCanada will win its court case, because NAFTA courts have traditionally

sided with the US. If the court did agree with TransCanada, the next president may have to make

a decision on whether to build or not. However, ignoring what fracking or tar sands may do to

the climate, one thing to keep in mind is the devastation it can cause, especially in the

agricultural heart of America. Although the pipeline may have been built with good intentions,

the environmental destruction it would cause is not worth the risk of being built, especially

because the majority of jobs would be construction and would leave after the project had been

completed.

President Obama’s administration has said that he would choose the course that would

get the United States off of dirty fuel and onto clean energy, and the 2015 Paris Treaty started it.

If TransCanada does get the lawsuit filed and win their case, the next president may have to

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make a decision about the pipeline. However, NAFTA’s court has yet to release any statement

on TransCanada’s lawsuit against the US State Department, and the next president may have to

make a decision similar to President Obama, where they must balance the economic gains

against the environmental destruction and devastation the pipeline would bring.

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Bibliography

Biello, David. “Keystone XL Oil Pipeline Exacerbates Climate Change.” Scientific American. 17

April 2013. Web. 7 March 2016.

Boos, Robert. “Keystone Pipeline and Government ‘Disrespect’.” Public Radio International:

Science, Tech & Environment. Public Radio International, 19 February 2015. Web. 21 April

2016.

Clark, Bob. “Keystone XL Pipeline.” Montana Sierra Club. Sierra Club. N.d. Web. 17 February

2016.

Edwards, Haley Sweetlands. “Keystone Pipeline Decision Challenged in Shadowy ‘Court’.”

Time Politics. Time Magazine, 7 January 2016. Web. 21 April 2016.

Eilperin, Juliet. “The Keystone XL Pipeline and Its Politics, Explained.” The Washington Post

Fix. The Washington Post. 4 February 2014. Web. 17 February 2016.

Eilperin, Juliet and Mufson, Steven. “As House Approves Keystone Pipeline Bill, Obama veto

Grows More Likely.” The Washington Post Politics. The Washington Post. 14 November 2014.

Web. 20 April 2016.

Eilperin, Juliet and Zezima, Katie. “Obama Vetoes Keystone XL Bill.” The Washington Post

Politics. The Washington Post. 24 February 2015. Web. 19 April 2016.

Finkel, Madelon L., Law, Adam. “The Rush to Drill for Natural Gas: A Public Health

Cautionary Tale.” American Journal of Public Health. American Public Health Association

101:5 (2011): 784-785. Web. 9 March 2016.

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“Growth of Tar Sands Across the Midwest.” National Wildlife Federation. What We Do:

Confronting Climate Change. N.d. Web. 20 April 2016.

Hertzler, Patricia Carroll. “Regulation of Hydraulic Fracturing Operations at the Federal and

State Levels.” American Water Works Association 106:11 (2014): 58-65. Computers & Applied

Sciences Complete. Web. 5 March 2016.

“Killing KXL: How an Unlikely Coalition of Environmental Activists Stopped the Destructive

Tar Sands Oil Pipeline.” Natural Resources Defense Council Stories. Natural Resources Defense

Council. 12 August 2015. Web. 19 April 2016.

“Keystone XL Rejection Leads TransCanada to Sue Obama Administration.” CBC Canada.

CBA News. 6 January 2016. Web. 17 February 2016.

Lee, Kurtis. “Keystone XL Oil Pipeline: What You Need to Know About the Dispute.” LA

Times. LA Times, 6 March 2015. Web. 22 March 016.

Liptak, Kevin. “Obama Rejects Keystone XL Bill.” CNN Politics. CNN. 25 February 2015.

Web. 17 February 2016.

“Senate Vote 280-Defeats Keystone XL Pipeline.” New York Times Politics. New York Times,

18 November 2014. Web. 22 March 2016.

Shear, Michael D., and Davenport, Coral. “Obama Vetoes Bill Pushing Pipeline Approval.” New

York Times Politics. New York Times, 24 February 2015. Web. 22 April 2016.

Song, Lisa. “Keystone XL Primer: How the Pipeline’s Route Could Impact the Ogallala

Aquifer.” Inside Climate News. Inside Climate News, 11 August 2011. Web. 21 April 2016.

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Spalding, Roy F. and Hirsh, Aaron J. “Risk-Managed Approach for Routing Petroleum

Pipelines: Keystone XL Pipeline, Nebraska.” Environmental Science & Technology 46.23

(2012): 12754-12758. Business Source Premier. Web. 5 March 2016.

Swift, Anthony. “Nebraska’s Court Ruling Deeming Keystone XL’s Route Void Is a Win for

Landowners, Water and Climate.” Natural Resources Defense Council. Natural Resources

Defense Council, 21 February 2014. Web. 21 April 2016.

“TransCanada Challenges Keystone XL Denial.” TransCanada. TransCanada. N.d. Web. 17

February 2016.

United States. Department of State.

United States. Environmental Protection Agency.

United States. Roosevelt Room. Statement by the President on the Keystone XL Pipeline.

Washington: 2015. Web.

Warrick, Joby, Mooney, Chris. “196 Countries Approve Historic Climate Agreement.” The

Washington Post. The Washington Post. 12 December 2015. Web. 9 March 2016.