Recent technology breakthroughs have unlocked the potential production of many billions of barrels of Alaska’s high viscosity heavy oil, a development not yet accounted for in U.S. climate strategy. Federal intervention is needed now to keep this heavy oil carbon bomb in the ground.

Pacific Environment, alongside other environmental groups, filed a legal petition this week asking the Department of the Interior for a new analysis of the climate damage and other harms related to the Trans-Alaska Pipeline System (TAPS). The petition was filed by the Center for Biological Diversity, Pacific Environment, Sovereign Iñupiat for a Living Arctic, Alaska Community Action on Toxics, Fairbanks Climate Action Coalition, and Public Employees for Environmental Responsibility.

Right now, more than 5 billion barrels of previously unrecoverable Alaska North Slope (ANS) heavy oil appear commercially feasible to produce using polymer flooding technology. For comparison, the sprawling, massive Willow field—development approval of which by the Biden administration last year sparked widespread objection because of the impacts to the climate, communities, and wildlife—is estimated to have 576 million barrels of recoverable oil reserves. The potential and incentive to produce the massive, viscous, and heavy oil accumulation larger than Willow is a huge, dangerous development for the climate.

It’s time for the Department of the Interior to review the nearly 50-year-old aging TAPS infrastructure and put a plan in place to decommission it.

The ANS heavy oil accumulation is enormous—large enough to qualify as a “carbon bomb” (greater than 1 gigaton of CO2 equivalent) with roughly 3 gigatons of CO2 emissions—and is Alaska’s largest prospective oil development. The accumulation contains an estimated 20 to 25 billion barrels, with more than 5 billion now commercially feasible to produce.

Although the international scientific consensus urges a rapid transition away from fossil fuels, Alaska crude oil production is projected to nearly double between 2024 and 2048, according to the U.S. Department of Energy’s (DOE) Energy Information Administration’s Annual Energy Outlook 2023.

The increase in Alaska production is driven by a combination of Willow, Pika, enhanced oil recovery in aging existing oil fields, and new enhanced oil recovery in previously uneconomic viscous and heavy oil formations using new polymer flooding technologies adapted for the Alaska North Slope. In contrast, the entire Lower 48 crude oil production is projected to be flat over the long run, growing by only one-twelfth of 1% (12.29 million barrels per day to 12.30 million b/d) from 2024 to 2048.

The heavy oil accumulation overlays deeper reservoirs on state-owned land in production for decades, including the Prudhoe Bay, Kuparuk River, and Milne Point units. ANS heavy oil, with a consistency ranging from molasses to tar, is extremely carbon intensive and is driving the greenhouse gas emissions intensity of ANS oil upward from already high levels, which have increased by 25% since 2012, according to California Air Resources Board greenhouse gas emissions estimates.

Polymer flooding technology for enhanced oil recovery was field tested and validated at the Milne Point Unit in a DOE-funded, four-year study that concluded in 2022, which dramatically improved the outlook for production of ANS heavy oil. The study was conducted by the University of Alaska, Fairbanks’ petroleum engineering department, with technical support from Hilcorp.

Because of the enormous climate impacts more heavy oil production would unleash, the Biden administration should act now to start a new environmental analysis that will evaluate and lead to implementation of remedial actions addressing climate impacts.

The existing environmental analysis of TAPS, now more than two decades old, fails to examine the climate harms of the extraction and burning of oil moving through the pipeline.

A Supplemental Environmental Impact Statement (EIS) process for TAPS should be initiated immediately to examine existing and potential climate impacts and the effects of using the heavy oil that could be transported through the nearly 50-year-old aging pipeline, among other issues.

During the past 45 years, TAPS has undergone two environmental assessments required by the National Environmental Policy Act (NEPA): the initial pre-construction EIS in 1972 and the Reauthorization EIS in 2002. NEPA requires that an existing EIS must be supplemented whenever there is new information or circumstances relevant to environmental concerns, or if there are significant environmental impacts that were not evaluated.

A lot has changed since 2002—more than 20 years of science have increased understanding of the causes, impacts, and necessary actions to address the climate emergency.The contributions of fossil fuels to greenhouse gas emissions have been irrefutably documented. Global climate change has accelerated with dramatically observable effects including the increase in the frequency and severity of climate disasters and disruptions and storms eroding the rapidly melting Arctic.

The prior EIS assessments did not sufficiently address climate impacts nor the impact TAPS will have as the infrastructure that delivers Alaska’s heavy oil to market.

The 2002 EIS contains this dubious prediction: “Carbon dioxide (CO2) emissions from TAPS would add little to the global CO2 concentration level.”

Neither outdated EIS discussed the fact that the 18.5 billion barrels of crude oil transported through TAPS already has contributed 9 billion metric tons of CO2 equivalent to the global atmosphere, including methane through leaks, venting, and flaring. The stale 2002 pipeline renewal EIS estimates refer only to emissions from the pipeline system itself (the pump stations, generators, etc.) and do not include the 92 million metric tons of CO2 per year currently associated with the crude oil that TAPS transports after it gets refined and burned.

Ironically, the physical stability of TAPS is threatened by thawing permafrost caused by fossil fuel-driven warming. The combination of advanced age and unstable land caused by thawing permafrost potentially jeopardizes the integrity of the pipeline and substantially increases environmental risk, including the increased potential for leaks and spills.

Under the current authorization the TAPS EIS will be reviewed again in 2032; however, changing circumstances and new information require that the Biden administration immediately reevaluate the TAPS authorization by initiating a Supplemental EIS process. New information since 2002 includes the commercialization of heavy oil and the listing of species as endangered including polar bears and ringed and bearded seals.

As the Trans Alaska Pipeline System approaches the end of its life, climate change is impacting Alaska and the Arctic region significantly. Alaska is warming faster than any other state and nearly four times faster than the global average.

By transitioning beyond fossil fuels, Alaska can build a thriving economy based on its abundant renewable energy resources, reduce energy costs for families and businesses, and increase the state’s energy security.

It’s time for the Department of the Interior to review the nearly 50-year-old aging TAPS infrastructure and put a plan in place to decommission it. How the TAPS is managed is key to America’s climate future.