Category Archives: Final Environmental Impact Statement (FEIS)

Final Response to FOIA: “No GIS Data”

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In their response to my FOIA request for the Keystone XL pipeline’s GIS data, including milepost marker longitude and latitude coordinates, the Department of State (DOS) has revealed that TransCanada did not supply the data and nor did the DOS request or require it. Without this digital mapping information, the Keystone XL’s Final Environmental Impact Statement (FEIS) and Supplemental Environmental Impact Statement (SEIS) are incomplete and cannot be evaluated for environmental impacts.

In their letter, the DOS stated:

Based on the subject matter of your request, we contacted the offices most likely to have responsive records: the Bureau of Oceans and International Environmental and Scientific Affairs; and the Bureau of Energy, Economics and Business. We were informed by employees familiar with the records and organization of those offices that the Department does not have copies of records responsive to your request because the Environmental Impact Statement for the Keystone pipeline project was created by Cardno ENTRIX under a contract financed by TransCanada Keystone Pipeline LP, and not the U.S. government. Neither Cardno ENTRIX nor TransCanada ever submitted GIS information to the Department of State, nor was either corporation required to do so. The information that you request, if it exists, is therefore neither physically nor constructively under the control of the Department of State and we are therefore unable to comply with your FOIA request.

Did the DOS, TransCanada, and Cardno ENTRIX all fail to perform due diligence in this case only – or is this standard operating procedure?

Last year when I requested the data from TransCanada, I was told that releasing it would be a “national security risk.” Despite this, TransCanada only carries $200 million in third party liability insurance. By contrast, cleanup costs for the 2010 pipeline spill in Kalamazoo, Michigan are $1 billion and climbing.

Why hasn’t TransCanada supplied, Cardno ENTRIX seen fit to include, or the DOS requested, electronic data of such national importance?

Last week President Obama said

I know there’s been, for example, a lot of controversy surrounding the proposal to build a pipeline — the Keystone pipeline, that would carry oil from Canadian tar sands down to refineries in the Gulf. The State Department is going through the final stages of evaluating the proposal. That’s how it’s always been done.

But I do want to be clear. Allowing the Keystone pipeline to be built requires a finding that doing so would be in our nation’s interest.

How does the DOS evaluate such national security, economic, and environmental interests without the electronic data?

Evidently, the Keystone Mapping Project knows more about the Keystone XL pipeline route than the United States Government.

DOS Final FOIA Response Keystone XL GIS data request
DOS Final FOIA Response Keystone XL GIS data request

FOIA Update: Taskers

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Since December I’ve made close to two dozen calls to the friendly and professional staff at the Department of State in an effort to track down my FOIA request.

Early on, the Office of Environmental Quality and Transboundary Issues referred me to the Bureau of Oceans and International Environmental and Scientific Affairs. I explained the whole matter of milepost markers and waterbody crossings to the kind woman there – only to learn, over a month and five calls later, that she was transitioning out of the job. Her parting voice mail assured me that the DOS had the GIS information I was looking for and that a new report from TransCanada would be coming out soon. Many calls later, the best her replacement could do was to say that she didn’t have a response for me. I think she got tired of my follow up calls, though. Another month later, in mid-March, I received an email from the person reviewing my request, saying:

Since you have exchanged messages and have spoken on the phone with various of my colleagues concerning your above referenced case, I just wanted to let you know that I was assigned as reviewer; that I have finished my work; and that I am therefore sending the case for senior review. I hope that the case will be concluded in the very near future.

“Finally, pay dirt!” I said to myself. A year after filing my request I was going to receive a response. The thing is, he didn’t send along his number. I waited. Emailed. Waited some more. Six weeks later I tracked him down and left a message.

Turns out, he had written me a letter and it was sitting over in Legal waiting for review. Over the ensuing weeks I left more messages and sent a couple of emails and there my letter sat in Legal. I imagined it buried under other letters just like it in the “In” box, waiting it’s turn.

I tried to not take it personally, but yes, the reviewer, too, tired of me. He passed me off to the Public Liaison, a cheerful woman who insisted she was going to get to the bottom of it. She explained the whole FOIA process to me. My request would have a tracking number assigned to it. Then it would be checked that it was valid and, indeed, something the DOS could respond to. For the first time it occurred to me that the DOS could be getting totally bizarre FOIA requests for such things as Wayne Shorter’s overseas play lists or pizza recipes used in Ghana.

My request would than be assigned to a geographic team and a privacy team, where a case analyst would conduct a review and do cable searches before sending it out to “taskers” to find the data. The final step would find my request returned for review and evaluated for how it fit with the law.

Come again? I did all that tasking a year ago! I told them who to call. Gave them the numbers. Yet, there the letter sat.

I’ve been assured I’ll get it any day.

The Narrative

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New to the KMP is the news feed in the footer. I call it the Narrative for the media’s influence on the public discourse. Often the discussion is not substantive.

Driving much of the public’s perception of the Keystone XL is the media’s horse race mentality – in this case, editorial and opinion pieces often based on misinformation. To quote Marshall McLuhan, “The medium is the message.”

The most common myths being perpetuated:

  • Myth 1: The Keystone will create thousands of jobs. To the contrary, only 36 jobs will be created.(US Department of State Keystone FEIS)
  • Myth 2: Since the Keystone’s Canadian oil supplants Mideast oil, it increases energy security for the US. To the contrary, the diluted bitumen piped through the Keystone will be traded on world markets, primarily to China. (Verlager). Also, in this age of global warming where green tech is clearly the future, doubling down on fossil fuels could be interpreted as making the country less secure.
  • Myth 3: The Keystone will lower US gas prices. To the contrary, by relieving a delivery bottleneck of midwest oil to Gulf Coast refineries, the Keystone will actually increase gas prices in the midwest. (Verlager)

Other common myths are addressed in this website’s blog.

Keystone (Secret) Comments

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It seems that with the Keystone XL, everything is secret – even the public comments to the Department of State’s (DOS) FEIS. You’ll have to file a FOIA request to get them.

Official comments to the DOS are due April 22 and should be sent to keystonecomments@state.gov. I’m posting a copy of my comments below. Feel free to copy your own below, as well. Alternatively (or additionally), 350.org has a convenient comments submission form here.

My comments to the DOS:

———————————————-

After careful review, I have found the FEIS and SEIS for the proposed Keystone XL project lacking in key data and detail that preclude a proper evaluation of the Keystone XL’s environmental impacts. Of greatest concern are the insufficiency of both the GIS routing data and spill mitigation details in the report.

Inadequate Data

Conspicuously missing from the FEIS and SEIS are the location data for the pipeline’s key landmarks, including milepost (MP) markers and waterbody crossings. Despite their absence, the MP markers are repeatedly referenced throughout both the project and DOS documents and are critical for all discussions of the pipeline route, potential environmental impacts, and surrounding points of interest.

In regards to the SEIS specifically, the GIS data contributed by the Nebraska Department of Environmental Quality (NDEQ) is inadequate for the following reasons:

  • Milepost Markers: The NDEQ report furnishes MP markers for even miles only, whereas the FEIS requires accuracy to the nearest tenth of a mile.
  • Waterbody Crossings: The NDEQ acknowledges that the Nebraska Keystone route has 163 waterbody crossings, but the NDEQ’s digital map file only contains the five largest.
  • Gas & Water Wells: The gas and water well data contained in the FEIS has not been updated to reflect the revised Nebraska route.

While all parties, including PHMSA, FERC, and all state agencies, acknowledge that the pipeline’s GIS data is public information, neither the DOS nor TransCanada will release this information. The hardcopy maps in the FEIS do not contain longitude and latitude information. TransCanada’s manager of Stakeholder Relations, Terry Cunha, has gone so far as to claim that the Keystone XL route location data is a matter of national security. If this is true, this danger has not been conveyed to the public nor acknowledged in the subject Report. The Report and the FEIS on which it relies cannot be considered suitable for public review until a complete open-source digital dataset has been made readily available at no cost.

Inadequate Spill Mitigation

The FEIS and SEIS also fail to sufficiently addresses TransCanada’s preparation for spill prevention and mitigation. It is alarming that TransCanada has yet to develop an Emergency Response Plan for the Keystone XL. A non-profit group, Plains Justice, brought these deficiencies to public attention over two years ago in their report, The Northern Great Plains at Risk: Oil Spill Planning Deficiencies in Keystone Pipeline System. Given the experience of the 2010 pipeline spill in Kalamazoo, Michigan, where cleanup costs are $1 billion and climbing, TransCanada’s $200 million third party liability insurance is grossly inadequate. Permitting should also be subject to EPA review. It would be negligent to repeat the Gulf Coast approval process, whereby USACE gave sweeping project-wide construction approval to TransCanada through a Nationwide Permit 12 and withheld waterbody crossing data until after granting their approval.

It is disturbing that TransCanada has not been required to fully disclose details of the pipeline route to the public or to document adequate emergency spill response measures. The public review process requires more accurate and complete information than have been provided to date by TransCanada, the DOS, and all state agencies regulating the pipeline.

Sincerely,

Thomas Bachand

The Keystone Fiction

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Recently, a reader asked me about an existing right-of-way visible on Google Earth that follows parts of the planned Keystone XL corridor. In some areas the projected route can be seen to directly overlay this visible right-of-way; at others it is adjacent or diverges sharply. Similar convergences and differences can also be seen in the official data. The multiple official sources I use typically align, but at times, they don’t. What accounts for this?

We can only conjecture explanations for what we are seeing:

  1. Is TransCanada following an existing easement when possible? Perhaps their leases with landowners allow them to put in multiple pipelines. Some states, like Montana, regulate pipelines stringently, others, like Oklahoma, appear to hardly regulate at all.
  2. Is TransCanada widening an existing easement?
  3. Does TransCanada only survey the route when they’re on the ground, ready to dig? The FEIS shows no survey procedures. Is the route created on a computer and no one actually steps on the ground until they show up at your property line – then they’ve got a 500 foot easement so they can adjust for real-world conditions? The regulatory disparities between various state agencies are broad and, again, the FEIS does not specify. Again, Montana stipulates surveying. Oklahoma is a black box.
  4. Are the FEIS maps and data tables accurate?
  5. All of the above.

Unfortunately, the incomplete nature of the FEIS and the opacity of the review process have made it impossible to verify the report’s veracity and determine the environmental impacts of the pipeline. The KMP primarily focuses on the absence of route data. Yet with other glaring deficiency in the FEIS coming to light, such as TransCanada’s inability to draw up an Emergency Response Plan and the paltry third-party insurance liability of $200 million, one has to wonder what else is remiss with the FEIS.

That’s the thing about environmental impact statements: initially they’re written by those with an interest in the project’s completion. They should be considered a work of fiction until proven otherwise. In the case of the Keystone XL, both the FEIS and the SEIS were produced by companies that had previously worked for TransCanada, Cardo Entrix and ERM, respectively. The Department of State is okay with this. While legal challenges can bring transparencies to an EIS, in the case of the Keystone XL Gulf Coast segment, landowner lawsuits and challenges by the Sierra Club were stymied and EPA review prevented when the US Army Corps of Engineers approved a Nationwide Permit 12 for the project.

The challenges to the Keystone XL are highlighting the business-as-usual approach to pipeline approval. The one-size-fits-all approval process does not seem to take into account the type of petroleum being transported by the Keystone, the Canadian ownership of the pipeline, nor its intended export to Asian markets.

We see this opacity being underscored in last week’s bitumen pipeline rupture in an Arkansas community. Was the community aware that they were living adjacent to a diluted bitumen pipeline? Was Exxon’s mitigation plan cleared with authorities? Why is Exxon controlling journalist access, including the airspace above the spill? Why aren’t companies transporting diluted bitumen contributing to the government’s clean-up fund, the Oil Spill Liability Trust Fund?

I suppose the greater question is: why are pipeline supporters so afraid of the facts?

FOIA Update: Non-expeditious Denial of Expeditious Processing

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On June 26, 2012, I wrote about my appeal of the Department of State’s (DOS) Denial of Expeditious Processing of my FOIA request for GIS route information. At the time, the United State Army Corps of Engineers (USACE) was considering a Nationwide Permit 12 for the Gulf Coast segment of the Keystone route, thereby bypassing EPA review of the pipeline’s waterbody crossings. As my appeal noted, without public disclosure of the milepost and waterbody GIS data, approval of the Gulf Coast Keystone route was bypassing public review:

Public is Being Denied Due Process

Despite the denial of the Presidential Permit, construction of the Keystone XL is currently underway. TransCanada, a foreign company, has been accused of using dubious means to gain right-of-way to private property, including the declaration of eminent domain. Currently, TransCanada is seeking expedited permitting by the Army Corps of Engineers for the Gulf Coast route. The Army Corps has promised to reply by June 26. While individual property owners are certainly aware of the pipeline’s presence, the wider community and citizens around the country are unable to make a proper review of the project without the MP and GIS data. To release key data only after landowners have undergone substantial hardship or the project is completed, would be to deny landowners, communities, and the public due process.

USACE approved the Gulf Coast Segment in early August of 2012 without fully disclosing the route or waterbody crossings. Eventually, an environmental non-profit forwarded me a number of TransCanada documents obtained through the FOIA process that contained the waterbody data.

It was not until January of this year that I discovered that, on July 12, 2012 (nearly a month before USACE issued its permit), the DOS had written – yet failed to send – me a letter denying my appeal for the expeditious processing of my FOIA request for GIS routing data. Incredibly, in their letter the DOS claims that this case is not eligible for expedited processing as it does not involve “Loss of substantial due process rights” – this despite the lack of transparency in DOS and USACE processes and the eminent domain proceedings being brought against Texas landowners by TransCanda, a Canadian company. The letter is below.

As the one year anniversary of my FOIA request approaches, I have made nearly a dozen calls to the DOS, speaking to numerous individuals in an effort to determine the disposition of my request and, for that matter, whether the DOS even has the GIS route data. I received a polite email from a gentleman at the DOS the other day saying that my request would be addressed shortly, to please stop calling, and to contact him with any questions. He didn’t include his number.

Department of State Denial of Expeditious Processing, Page 1
Department of State Denial of Expeditious Processing, Page 2

Map: Gulf Coast Waterbody Crossings (partial)

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As the disasterous Kalamazoo spill highlights, the Keystone XL’s waterbody crossings pose an extreme environmental threat. Yet, while the Department of State’s (DOS) Final Environmental Impact Statement (FEIS) does identify the pipeline’s waterbody crossings and references them by milepost (MP) marker, neither the DOS, TransCanada, nor the United States Army Corps of Engineers (USACE) will release the location data for the MP markers.

In mid-July that changed somewhat when environmental groups obtained, through Freedom of Information Act (FOIA) requests, Gulf Coast waterbody crossing data for the Tulsa and Galveston District offices of USACE. Missing still is data from the USACE Fort Worth District Office. USACE offices only release the data after the offices have approved TransCanada’s application for a Nationwide Permit 12 (NWP 12). The NWP 12 allows the company to sidestep case-by-case waterbody environmental review by giving blanket approval for the entire route. While it is disheartening to see the pattern of obfuscation established by TransCanada and the DOS, adopted by USACE, it’s not surpising.

Construction of the Keystone’s Gulf Coast route began on Monday. The only obstacles remaining for TransCanda are a few landowner lawsuits and the Sierra Club.

The Keystone fight has also brought into question the use of eminent domain by private companies. One has to wonder how many landowners would have challenged TransCanada more forcefully had they not been bullied by eminent domain proceedings.

Updated to show the Waterbody Crossings, the new Keystone Mapping Project Google Earth view can be downloaded here:

A 2D map may be viewed here.

FOIA Update: Dept of State Stonewalling Public Review

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I have been told that the main obstacle to my Freedom of Information Act (FOIA) request with the Department of State (DOS) for the milepost data for the Keystone XL is that the information is “politically sensitive.”

To say the least, this stonewalling is disconcerting. A foreign corporation is abusing common carrier status to declare eminent domain on the property of American citizens so that it can build a diluted bitumen pipeline through America’s heartland and expedite delivery of its product to world markets. While this project will threaten our groundwater, waterways, and general health, increase gas prices and world dependency on oil, and further forestall a necessary shift to a green economy (Read more: TransCanada: “Keystone XL National Security Risk”), President Obama is expediting pipeline construction and has remained mute on global warming.

Whose interest is the White House and the DOS representing?

On April 12th I filed a FOIA request for the release of the milepost location data (which, according to both federal and state agencies, is public information) for the proposed Keystone XL pipeline. As FOIA requests with the DOS can take five to twelve months, I requested expedited service. This part of my request was rejected, I appealed, and am still waiting to hear back:

This email is to appeal your Denial of Expedition of FOIA request F-2012-XXXXX.

As you must be aware, the proposed Keystone XL pipeline, which will stretch through the American heartland from the Canadian border to Port Arthur, Texas, is of great interest to communities throughout the country. The release of the pipeline’s milepost (MP) marker longitude and latitude data and GIS information is of urgent importance for the following reasons:

1. MP Location Data is Required by the FEIS.
The MP location data is referenced throughout the Department of State’s Keystone XL FEIS. Without this information one cannot make a proper evaluation of the original Keystone XL FEIS, the revised Keystone application submitted on May 4, 2012, the Gulf Coast Route now being considered by the Army Corps of Engineers, or the entire project’s environmental impacts. In fact, the absence of this key reference data calls into question the completeness of the FEIS and the review process.

2. MP and GIS Location Data are Public Information
Federal and state agencies consider oil and gas pipeline GIS data to be public information. Such agencies include the Federal Energy Regulatory Commission (FERC), the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA), the Texas Railroad Commission, the Montana Department of Environmental Quality, and the South Dakota Department of Environment and Natural Resources. By withholding this information and requiring a FOIA request, the Department of State is unnecessarily hindering the public review process.

3. Public is Being Denied Due Process
Despite the denial of the Presidential Permit, construction of the Keystone XL is currently underway. TransCanada, a foreign company, has been accused of using dubious means to gain right-of-way to private property, including the declaration of eminent domain. Currently, TransCanada is seeking expedited permitting by the Army Corps of Engineers for the Gulf Coast route. The Army Corps has promised to reply by June 26. While individual property owners are certainly aware of the pipeline’s presence, the wider community and citizens around the country are unable to make a proper review of the project without the MP and GIS data. To release key data only after landowners have undergone substantial hardship or the project is completed, would be to deny landowners, communities, and the public due process.

4. Keystone Mapping Project Disseminates Routing Data to the Public
My Keystone Mapping Project (KMP: https://keystone.steamingmules.com) will incorporate the MP and GIS data into its current online maps. The KMP, as the most comprehensive source of routing data for the Keystone XL, is referenced by major news organization, such as NPR, and viewed widely by landowners, researchers, educators, and the public.

Clearly, there is a compelling need for an immediate release of the Keystone XL MP and GIS data. Not only is the data required for proper review of the project but, with the Army Corps of Engineers permitting date for the Gulf Coast route less than three weeks away, it is imperative that accurate MP and GIS data be released immediately. The American public deserves the opportunity of both review and oversight.

As I post this, the Army Corps of Engineers has begun approving the necessary permits for the Gulf Coast route, thus maintaining its poor record on environmental stewardship. Even so, considering the effort I’ve expended in obtaining a data file that resides in the public domain from the DOS, the 45-day permit turnaround by USACE for a construction project that crosses two states is impressive.

Move along. There’s nothing to see here.

TransCanada: “Keystone XL National Security Risk”

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The guy in TransCanada’s Data Integrity Program was very friendly, but once he found out I wasn’t with the company he said “You’ll have to talk to Public Relations.” He wouldn’t say why. It took me a while to track down PR’s phone number, only to have neither my calls nor emails returned. It didn’t seem like very good PR. Then again, I was asking for the milepost marker longitude and latitude data for TransCanada’s proposed Keystone XL pipeline as referenced throughout the Final Environmental Impact Statement (FEIS) published on the Department of State (DOS) website. Why would PR have this information? I was confused.

I called TransCanada Stakeholder Relations and spoke to a very nice woman who said that TransCanada doesn’t release the milepost data so as to protect landowners. That didn’t make sense because many landowners are angry with TransCanada for making dubious use of common carrier status (typically used for telephone and public utility cables and pipelines) in order to declare eminent domain and force a right-of-way for their pipeline upon property owners. She clarified that they were protecting from public retribution those landowners who had signed leases. Evidently, someone’s car was vandalized. What about the communities directly impacted by the pipeline? She didn’t know. And how is one supposed to make sense of the FEIS without the oft-cited milepost data? She said that the milepost markers would be finalized and made public when the pipeline was completed and operating. Wouldn’t that be a little late? The whole point of public review was to look at the project ahead of time, no? Or maybe that was TransCanada’s point. Anyway, if I really wanted the milepost information, she helpfully suggested, I could overlay the striped-down FEIS maps, which have been purged of all longitude and latitude information, onto real maps and get the location information that way. I was getting more confused. It was nice that she acknowledged the information was public, but it seemed like a waste of effort when they could just give me the data.

Then I read TransCanada CEO Russ Girling’s opinion piece in the New York Times, in which he said,

Our plan has undergone well over three years of environmental review by numerous reputable federal and state agencies. The review was the most comprehensive process ever for a cross-border pipeline.

I was buoyed to hear that TransCanada was as concerned for America’s safety as I, so I called the office of Sean McMaster, the Vice President of Stakeholders Relations. Certainly, he would help me make sense of the FEIS and release the milepost data. My calls went unreturned. Eventually I was connected to the Vice President of Public Sector Relations, who said I was the only one ever to request the Keystone milepost data. Someone would get back to me, he said. He wasn’t sure why the information wasn’t available and then added the caveat, or what the information is. It only confused me more that the Vice President of Public Sector Relations for a company striving to be the “leading energy infrastructure company in North America” did not know about milepost markers.

Eventually, Terry Cunha, Manager of Stakeholder Relations for the Keystone called me. Mr. Cunha said that milepost data was a matter of national security and that the information had been released to regulators. If the public knew where the pipeline was, he said, “They could impact it. They could drop a backhoe on top of it.” I reminded him that both the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Energy Regulatory Commission (FERC) regard pipeline data as public information. Furthermore, the states of Texas and Montana post the proposed Keystone XL route on their web sites – it’s just the milepost data that is missing, preventing one from making a complete analysis of the FEIS. In fact, a friendly fellow at FERC told me that physical stakes would mark the mileposts just for the reason cited by Mr. Cunha: construction crews need to know where pipelines are buried.

“We’re not going to give it to you,” Mr. Cunha said bluntly.

With no one left to call, I had become dizzy with confusion, as if I was breathing the benzene released by a diluted bitumen spill. My questions have only multiplied:

Which regulators have received the milepost data? PHMSA does not get the information until after the project is approved. Regulators in the states of South Dakota, Nebraska, Oklahoma, and Texas all claim to have not received the data. My FOIA request to the DOS is anticipated to take 5 to 12 months.

As the FEIS is incomplete without the milepost data and, as I am the only one in the country to request the milepost data (according to both TransCanada and the DOS), on what basis does TransCanada CEO Russ Girling claim “The review was the most comprehensive process ever for a cross-border pipeline?”

Why has TransCanada failed to notify the public that the Keystone XL presents a “national security” risk?

How do American military service personnel and veterans feel about a foreign corporation hiding behind “national security” when withholding critical environmental review information concerning the company’s private diluted bitumen (tar sands) pipeline bisecting the American heartland?

Next week the US Army Corps of Engineers is going to make a determination on TransCanada’s application for a Nationwide Permit 12, which will sidestep EPA oversight and threaten hundreds of waterways (651 in Texas alone).

Is this the national security risk TransCanada is referring to?

Oklahoma Keystone XL Route

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UPDATE 6.6.12: The route published here does not represent the unpublished route changes made after Novemeber 2011. [more]

After President Obama denied approval of the Keystone XL, TransCanada Corporation (a Canadian company) repackaged the pipeline project and broke it into three separate projects:

  • The new Keystone XL Pipeline application largely bypasses the Nebraska Sandhills area and now terminates in Steele City, Nebraska.
  • A second project, the Keystone Pipeline Cushing Extension, connects the pipeline to facilities in Cushing, Oklahoma.
  • A third and final project, Keystone Pipeline Gulf Coast Project, intends to reach the pipeline terminus at Port Arthur, Texas.

For TransCanada Corporation, the advantage of this project reconfiguration is that the Gulf Coast Project is now an American domestic project and does not require approval by the US Department of State.

This change of events has accelerated both construction and interest in the Gulf Coast route. While residents of Oklahoma and Texas would like to know the details of the pipeline route, neither state or federal agencies will release it. To partially resolve this issue, I have updated the online maps by approximating the Oklahoma route from the route sheets included in the Keystone FEIS, published on the Department of State website (below). As the PDF route sheets do not contain latitude, longitude, or milepost information, they are unsuitable for evaluating the FEIS. Regardless, the online maps appear to be accurate within 50 feet and the PDF route sheets may be of value to landowners as they walk their property.

Oklahoma Route Sheets
2010 Keystone XL FEIS, Volume 4, Appendix C (17.5 MB) »»

The Missing Milepost Markers

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There are two types of data that make up the maps on this site:

  • GIS route longitude and latitude data and
  • Milepost (MP) marker longitude and latitude data.

GIS Route Data: An Approximation

Perhaps of greatest interest to the public, is the GIS route data. This information is represented by the black line on the KMP maps, showing the route and its various twists and turns. Property owners and citizens look to this information to learn where the pipeline will cross their property line and how it might affect their communities. The wider public gains an immediate sense of the pipeline’s scope.

The route line, though, is merely an approximation. It represents a wider corridor (500 feet in the case of Montana and 2,000 feet for Nebraska),in which the actual pipeline construction will take place. This allows for engineers and construction crews to adjust to conditions on the ground. The downside of this corridor concept is that it can introduce uncertainty and opacity into the process, making it more difficult for communities and stakeholders to review the project.

Milepost Markers: The Key Reference Point

Crucial to the environmental review process are the MP markers. During a project’s proposal stage the MP markers represent the center-line of the corridor. They are referenced throughout the Keysone XL FEIS and are vital to interpreting any analysis found there. In the case of the Montana segment of the Keystone XL, the MP markers are in increments of one-tenth of a mile. The corridor itself is 500 feet wide. Thus, the area between MP markers is 500′ x 528′, or approximately 6 square acres – an area that is comprehensible, whether one is standing on the ground or envisioning the area on a map. By contrast, the 2000′ corridor presented in the Nebraska application, at over one-third of a mile, is likely to stretch out of view and be of less utility.

After the pipeline is completed the MP markers are readjusted so that they are no longer figurative points in space, but correlate directly to physical stakes placed in the ground above the buried pipeline. These points are added to the national database of oil and gas pipelines.

Lack of Transparency by Project Sponsors: FEIS Questionable

In regards to the proposed Keystone XL, neither TransCanada nor the Department of State will release either the GIS route data or the MP data. While both Texas and South Dakota have made the route data available, only Montana has released both the route and MP data. The lack of transparency by both the project’s sponsor and the DOS, calls into question the process leading to approval of the FEIS and, thus, the viability and true consequences of the Keystone XL itself.

For more information read the Keystone Mapping Project About page.

Keystone Mapping – Site Launch

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A couple of months ago I decided to take a look at the Final Environmental Impact Statement (FEIS) for the proposed Keystone XL pipeline that is planned to run from Alberta, Canada to Houston, Texas. TransCanada Corporation aims to deliver Canadian tar sands oil to southern US refineries and ports. The environmental implications of this project are tremendous.

Conspicuously missing from the FEIS are the pipeline’s GIS route and milepost marker (MP) location data. The MP data are referenced throughout both the project and Department of State documents and are a key reference for all discussions of the pipeline route, potential environmental impacts, and surrounding points of interest. After my routine request for public pipeline milepost data turned into a bureaucratic run-around, I sought out alternative sources for this information by which to create the partial route and MP maps found on this site. Stay tuned as additional requests are pending.

If the American public is going to make an informed and prudent decision on the proposed Keystone XL pipeline, they will require accurate and comprehensive information presented in a cogent and easily accessible manner. I hope that this site is a step in that direction.