Appears to have been written by a contractor for TransCanada!! for an undisclosed amount of money
Amazingly enough, Toe, that's how it's normally done. INTERIM GUIDANCE FOR THE USE OF THIRD-PARTY CONTRACTORS IN
PREPARATION OF ENVIRONMENTAL DOCUMENTS BY THE DEPARTMENT OF STATE
A “third party contractor” is a contractor that is selected by, chosen by and working under the direction of a federal agency, but that is being paid by the applicant.If you want your megaproject to go through, you pay for the required environmental impact study done by a third party contractor - hence the ERM-TransCanada 2012 contract.
If the State Dept did the work themselves, conflict-of-interest rules would kick in; not so with industry contractors who all have ties to each other.
The problem with the last two Keystone EIS's was that they were done by Cardno Entrix, a company with an existing relationship with TransCanada and on the recommendation of TransCanada to the State Dept! They also handled the State Dept pipeline webpage and all the public hearings on the pipeline.
I wrote about this here
in July/Sept 2011. Think Progress picked it up with more info - same writer you link to above - and 3 months later the NYT did an expose, causing a new EIS to be done.
The problem with the new contractor, ERM, is that while they don't have a prior direct
relationship to TransCanada, the point firmly made by the State Dept, they farmed the work out to other companies who do - like EnSysEnergy who work for Koch Industries. Koch's of course is where the pipeline starts.
Edit : added link to State Dept.