Mapping Data as Bargaining Chip for Indigenous Cooperation?

Lost on many is that over the decade that the Keystone XL (KXL) has been debated, the route has been altered a number of times but the publicly available maps have, either, not been updated or simply redacted altogether. Further, those maps that could be found were available only as non-machine readable PDF’s and were lacking key location information, making them essentially useless to all but the most tenacious cartographer.

Nowhere in the various environmental reports has the location data for thousands of referenced mileposts been made available. Want to know where any of the KXL’s nearly 4,800 waterbody crossings are? The 2019 report now reveals the closest milepost number but not the location data of that milepost. Making this shell game worse is, that as the route is adjusted and changed, the mileposts too change, but no record of changes are published and, thus, one version of the report cannot be reconciled against another. In short, without milepost data the reports and their analysis can not be evaluated.

As you may recall, TransCanada first claimed that the data was being withheld for national security reasons and, after it was pointed out that FERC considered the data public, TransCanada then claimed that they were protecting the privacy of cooperating land owners. Next, the Department of State (DoS) claimed they did not have the data. As this did not jibe with the fact that they required the data for their environmental reports, the DoS corrected themselves and said that while they had the data, they didn’t own it. This claim was not supported by their contract with TransCanada and ERM (the company that prepared the report), which stated that all data required by the report did, indeed, belong to the Department.

As we wait for the next steps to unfold in our ten-year FOIA saga with the DoS, we now discover on page 117 of the 2019 FSEIS, Vol II (App A-E):

“In August, 2018 the Department sent a letter to all consulting parties, including all tribes, announcing the establishment of an on-line Project cultural resources portal that enables large documents to be posted for download and review. In March 2019 the Department sent a letter to all consulting parties, including the tribes, notifying them that a GIS database had been added to the cultural resources portal. The GIS contains spatial data layers on all known cultural resources in relation to the pipeline ROW (right-of-way) as well as the ROWs for all other Project components including power stations, pump stations, power lines, access roads, pipe yards, etc. This allows the viewer to see the cultural resources data in a scalable format in relation to detailed information on the Project. “

From this we learn that TC Energy (formerly TransCanada) and DoS do indeed have the data, can compile the data, and are able to make it available. But there may be a rub.

Skip down to page 175 and we find nearly a hundred pages of comment letters from Indigenous tribes affected by the project. Of the many issues raised in the letters, two are of particular note here. First, the US Government has failed to meet its treaty obligations by not conducting government-to-government consultations. The only public meeting for the 2019 FSEIS was held in Billings, Montana in the midst of a blizzard. This required tribal representatives to travel 300 miles, after which they were made to wait outside in the snowstorm for the meeting to begin. When finally admitted, they were not permitted to ask questions. Second, by giving the environmental review short shrift, while also ignoring claims that the pipeline threatens both tribal drinking and agricultural water supplies, the US government has violated its trustee obligation to the tribes.

Thus, it is of no surprise that the tribes came to the conclusion that the environmental review process was illegitimate and was being conducted in bad faith. According to some, to participate in it would be seen to validate it.

So, in the case of the secret route data, is TC Energy attempting to trade it for tribal cooperation? If the tribes were to actively cooperate with TC Energy so as to receive the route data, could they undermine the defense of their sovereign rights?

To review the tribal letters, all official documents for the 2019 Keystone XL FSEIS can be found on this web page, including the Keystone XL Final SEIS, December 2019, Volume II: Appendix A Through Appendix E (50MB PDF).

Keystone Map Upgrades for Canada & Mobile Users

Significant upgrades, in both coverage and format, have been made to the Keystone Mapping Project maps. The Keystone and Keystone XL maps now include Canadian routes, as well as formats more suitable to mobile users.

The maps now include:

  • Canadian legs of both pipelines for full coverage from Alberta, Canada to the Gulf Coast of Texas. Please note that, like all KMP mapping data, the Canadian data is unofficial and cannot be found in the Department of State’s FSEIS.
  • In addition to the current hassle-free online centerline map, a Google Maps compatible version is available for those wishing to integrate additional map services.
  • For those working in the field offline, a mobile-compatible file is available for download.
  • The robust Google Earth version of the map with it’s many layers of additional data and corridor views, now also includes the unverified Canadian routes.

For more details on the upgraded and revised centerline routes, visit the Keystone Centerline Maps page.

Google Earth KML files can be found Google Earth Dowloads page.

Terms: Keystone Mapping Project map files are for personal use only. Publication, distribution, or posting to the Internet is not permitted without written permission. Please consider supporting this project with a donation. All site contents ©Thomas Bachand 2020. All Rights Reserved.

Map Upgrade: Keystone Pipeline North to South

In addition to the proposed Keystone XL, the Keystone Mapping Project (KMP) now includes the Keystone Pipeline route map through North Dakota, South Dakota, and Nebraska.

Initially, the KMP had only mapped the proposed Keystone XL, whose southern segment was called the Gulf Coast Extension. As originally envisioned, the Keystone XL route ran through Montana, South Dakota, Nebraska, Oklahoma, and Texas. While only the Oklahoma-Texas Gulf Coast Extension of the Keystone XL was built, its construction in 2014 allowed for the Keystone complex of pipelines to extend north-south across the United States. The Keystone’s northern segment was completed in 2010 and ran from the Canadian border, through North Dakota, South Dakota, and Nebraska. The following year it was connected to the the tank farm in Cushing, Oklahoma via the Kansas Keystone-Cushing Extension. From there, the Gulf Coast Extension completed the Canadian oil’s route to Gulf Coast refineries.

As the KMP published the Cushing-Extension Pipeline route last year, the addition of the Keystone ND, SD, and NE routes now completes the north-south mapping of the larger Keystone Pipeline complex. These new maps show both Keystone XL and Keystone entry points at the Canadian border and follow the two routes to the Gulf Coast.

To view the upgraded maps, visit the KMP map page.

Map Update: Keystone XL North

With the release of the Final Supplemental Environmental Impact Statement (FSEIS) by the Department of State (DoS) on January 31, 2014, one would think more clarity would have been brought to the Keystone XL route and the pipeline’s impacts. In January of 2013, I was told by the DoS that the agency had milepost data to 1/10th of a mile and that updated maps and waterbody tables would be included in an upcoming report. Now a year later, the report has just been released and, not only is the milepost data still missing, but updated route maps have been redacted “as sensitive information not for public distribution.” (Appendix B,C,&D). The Environmental Report’s author, Exponent, does not seem to be aware that both PHMSA and FERC consider pipeline data public and that the pipeline route will be easily located once construction begins. Upon completion, marker stakes will caution construction crews to the buried pipeline. The route maps from the 2008 FEIS and 2009 SEIS, sans latitude/longitude data, remain online.

Montana’s Department of Environmental Quality (MDEQ), South Dakota’s Department of Environment and Natural Resources (SD DENR), and the South Dakota Public Utility Commission (SD PUC) all claim that they do not have the most current route data. TransCanada will submit route data to these agencies after the White House approves the project and forty-five days before construction begins. Evidently, at that point the data ceases to be “sensitive.”

According the South Dakota Keystone Public Liaison officer – an appointee of the the SD PUC who is paid by TransCanada to deal with landowner issues, since 2009 many groups have been visiting South Dakota to survey the route, including Native American tribes, biologists, archaeologists, and engineers, related and unrelated to TransCanada. This indicates a much broader interest in the route. So why aren’t state and Federal agencies making this GIS data publicly available?

Now, courtesy of a Freedom of Information Act (FOIA) request, the US Fish and Wildlife Service has filled in in many of the gaps by releasing the August 2012 centerline map of the Keystone XL. For the Montana section this newly released route falls within the MDEQ’s currently publicized 500 foot corridor. The Nebraska segment is identical to the revised centerline route released in the May 1, 2013 SEIS. In contrast, the South Dakota route shows nearly 30 changes. Route changes can be cross referenced to tables on the DSEIS (8 MB) and FSEIS (8 MB).

Comments Due: Draft NDEQ Report

Comments are due December 4 on the Nebraska Department of Environmental Quality’s Draft Evaluation Report for the Keystone XL reroute around Nebraska’s Sandhills. A simple online form can be found here.

I have found the report lacking in supporting data. The report frequently references the Department of State’s FEIS and Transcanada, neither of which provide sufficient data to make a proper evaluation of the project.

My comments:


November 30, 2012

Nebraska Department of Environmental Quality
1200 “N” Street, Suite 400
P.O. Box 98922
Lincoln, Nebraska 68509

RE: Comments for October 2012 Draft Evaluation Report for the proposed Keystone XL project

After careful review, I have found the NDEQ’s October 2012 Draft Evaluation Report for the proposed Keystone XL project (Report) 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 and Over-Reliance on DOS FEIS

The NDEQ’s report relies too heavily on the Department of State’s Final Environmental Impact Statement (FEIS) in making its analysis and supporting its assertions. Conspicuously missing from the FEIS 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. The GIS data released by the NDEQ is inadequate, as well, 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

Neither the FEIS nor the NDEQ’s report 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 a recent 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 the NDEQ.


Thomas Bachand


Map: Eminent Domain – Texas

Keystone XL Eminent Domain filings by TransCanadaThe first installment of the eminent domain map is now online. We have begun with the state of Texas and will add more eminent domain data as it becomes available. If you would like to contribute data to this map:

The county data for Texas comes courtesy of State Impact Texas. Statewide there were 102 eminent domain filings by TransCanada. Landowners typically fall into one of three categories:

  • Those who have willingly signed a lease with TransCanada
  • Those who have begrudgingly signed so as to avoid legal action, and
  • Those who have been forced to give right away to TransCanada due to eminent domain proceedings.

Only the last group is represented in the map.

Map: Consolidated 2D View

Keystone XL Complete Google MapTo ease web viewing, the Keystone Mapping Project’s Google Map data has been consolidated into a single map. The Keystone XL – 2D Complete map contains available data for milepost markers, waterbody crossings, gas and water wells, and eminent domain filings. The map will be updated and expanded as more data becomes available, giving viewers a single resource for a cursory view of the Keystone XL pipeline. For now, the individual maps are also being maintained.

For those seeking more detail, the KMP Google Earth view remains the most comprehensive map of the Keystone XL.

Featured on NPR’s StateImpact Texas

The Keystone Mapping Project was featured on NPR’s StateImpact in Texas with an interview of KMP creator Thomas Bachand. In the interview, Bachand discusses his motivations for building the KMP and the widespread support the project has received. Click here to read Terrence Henry’s Q & A with Thomas Bachand.

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