The total direct and indirect emissions associated with the proposed Project would contribute to cumulative global greenhouse gas (GHG) emissions.  However, emissions associated with the proposed Project are only one source of relevant GHG emissions.  In that way, GHG emissions differ from other impact categories that all GHG emissions of the same magnitude contribute to global climate change equally, regardless of the source or geographic location where they are emitted.

Slide9Assuming construction of the proposed Project were to occur in the next few years, climate conditions during the construction period would not differ substantially from current conditions.  However, during the subsequent operational time period, the following climate changes are anticipated to occur regardless of any potential effects from the proposed Project:

  • Warmer winter temperatures;
  • A shorter cool season;
  • A longer duration of frost-free periods;
  • More freeze-thaw cycles per year (which could lead to an increased number of episodes of soil contraction and expansion);
  • Warmer summer temperatures;
  • Increased number of hot days and consecutive hot days; and
  • Longer summers (which could lead to impacts associated with heat stress and wildfire risks).

This Supplemental Environmental Impact Statement (EIS) assessed whether the projected changes in the climate could further influence the impacts and effects attributable to the proposed Project.  Elevated effects due to projected climate change could occur to water resources, wetlands, terrestrial vegetation, fisheries, and endangered species, and could also contribute to air quality impacts.  In addition, the statistical risk of a pipeline spill could be increased by secondary effects brought on by climatic change such as increased flooding and drought.  However, this increased risk would still be much less than the risk of spills from other causes (such as third-party damage).  Climate change could have an effect on the severity of a spill such that it could be reduced in drought conditions but increased during periods of increased precipitation and flooding.


The proposed Project would emit approximately 0.24 million metric tons of carbon dioxide (CO2) equivalents MMTCO2e (Million Metric Ton of Carbon Dioxide) per year during the construction period.  These emissions would be emitted directly through fuel use in construction vehicles and equipment, as well as, land clearing activities including open burning, and indirectly from electricity usage.

During operations, approximately 1.44 MMTCO2e would be emitted per year, largely attributable to electricity use for pump station power, fuel for vehicles and aircraft for maintenance and inspections, and fugitive methane emissions at connections. The 1.44 MMTCO2e emissions would be equivalent to GHG emissions from approximately 300,000 passenger vehicles operating for 1 year, or 71,928 homes using electricity for 1 year.

The total lifecycle emissions associated with production, refining, and combustion of 830,000 bpd of oil sands crude oil transported through the proposed Project is approximately 147 to 168 MMTCO2e per year.  The annual lifecycle GHG emissions from 830,000 bpd of the four reference crudes examined are estimated to be 124 to 159 MMTCO2e.  The range of incremental GHG emissions for crude oil that would be transported by the proposed Project is estimated to be 1.3 to 27.4 MMTCO2e annually.  The estimated range of potential emissions is large because there are many variables such as which reference crude is used for the comparison and which study is used for the comparison.


The proposed Project route would avoid surface water whenever possible, but would cross approximately 1,073 surface waterbodies including 56 perennial rivers and streams as well as approximately 24 miles of mapped floodplains. If permitted, Keystone would drill underneath major rivers to mitigate construction impacts.

The proposed pipeline would cross important aquifers such as the Northern High Plains Aquifer (NHPAQ) which includes the Ogallala Aquifer and the Great Plains Aquifer (GPA).  Modeling indicates that aquifer characteristics would inhibit the spread of released oil, and impacts from a release on water quality would be limited.

Nevertheless, within 1 mile of the proposed Project route are 2,537 wells, including 39 public water supply wells. Wells that are in the vicinity could be affected by a release from the proposed Project.

3.1        Surface Water – During Construction:

Construction of the proposed Project could result in temporary and permanent impacts such as:

  • Stream sedimentation;
  • Changes in stream channel morphology (shape) and stability;
  • Temporary reduction in stream flow; and
  • Potential for hazardous material spills.

Open-cut methods would be used at most waterbody crossings.  However, impacts to surface waterbodies would be mitigated through various means.  Horizontal directional drill (HDD) methods would be used at 14 major and sensitive waterbody crossings.  Waterbody banks would be restored to preconstruction contours or to a stable slope.  Seeding, erosion control fabric, and other erosion control measures would be installed, as specified in the CMRP and permit documents.

3.2       Surface Water – During Operations:

Potential impacts during the operations phase would include:

  • Channel migration or streambed degradation that exposes the pipeline;
  • Channel incision that increases bank heights to the point where slopes are destabilized, ultimately widening the stream; and
  • Sedimentation within a channel that triggers lateral bank erosion.

The proposed pipeline would be at least 5 feet below the bottom of waterbodies and at least 3 to 4 feet below the bottom of waterbodies in rocky areas, and that depth would be maintained at least 15 feet from either waterbody edge.

Where an HDD method is used, the crossing depth would be up to 55 feet below the stream bed. Potential bank protection measures could include installing rock, wood, or other materials keyed into the bank to provide protection from further erosion or regrading the banks to reduce the bank slope.


The US Fish and Wildlife Service (USFWS) identified 14 federally protected, proposed, and candidate species that could be affected by the proposed Project:  11 federally-listed threatened or endangered species, as defined under the ESA, one proposed species for listing as endangered, and two candidate species for listing as threatened or endangered.  Of the federally listed, proposed, and candidate species, the endangered American burying beetle (Nicrophorus americanus) is the only species that is likely to be adversely affected by the proposed Project.  Other species could potentially be affected by the proposed Project; among these are whooping cranes (Grus Americana), greater sage-grouse (Centrocercus urophasianus), and Western prairie fringed orchids (Platanthera praeclara).

Approximately 83 miles of the proposed Project Route in South Dakota and Nebraska would affect suitable American burying beetle habitat.  Consultation between the Department and USFWS resulted in development of conservation measures and compensatory mitigation, such as trapping and relocating beetles, special lighting restrictions (the beetles are attracted to light), and establishment of a habitat conservation trust.

Even with these measures, the proposed Project would be likely to adversely affect the American burying beetle, resulting in incidental take (such as unintended death or harm of individual beetles) during construction or operation.  The combination of Keystone’s American burying beetle monitoring program and Reclamation Performance Bond would provide assurances that the acres disturbed by the proposed Project would be restored appropriately.  The USFWS concluded in the 2013 USFWS Biological Opinion that the proposed Project is not likely to jeopardize the continued existence of the American burying beetle.


The proposed route extends through relatively flat and stable areas, and the potential for seismic hazards (earthquakes), landslides, or subsidence (sink holes), is low.  The pipeline would not cross any known active faults. During construction, land clearing could increase the risk of landslides and erosion. Keystone would, if permitted, construct temporary erosion control systems and restore the Right of Way (ROW) after construction.

The proposed Project route would avoid the Nebraska Department of Environmental Quality – NDEQ-identified Sand Hills Region, where soils are particularly susceptible to damage from pipeline construction.  Potential impacts to soils resources in other areas associated with construction or operation of the proposed Project and connected actions could include soil erosion, loss of topsoil, soil compaction, an increase in the proportion of large rocks in the topsoil, soil mixing, soil contamination, and related reductions in the productivity of desirable vegetation or crops. Construction also could result in damage to existing tile drainage systems (an agriculture practice that removes excess water from soil subsurface), irrigation systems, and shelterbelts.

To mitigate and minimize these impacts, Keystone would, if permitted, put in place procedures for construction and operation that are designed to reduce the likelihood and severity of proposed Project impacts to soils and sediments, including topsoil segregation methods, and to mitigate impacts to the extent practicable. After construction, areas of erosion or settling would be monitored.


Potential construction- and operations-related impacts to general terrestrial vegetation resources associated with the proposed Project include impacts to cultivated crops, developed land, grassland/pasture, upland forest, open water, forested wetlands, emergent herbaceous wetlands, and shrub-scrub communities. In addition, the proposed Project route would result in impacts to biologically unique landscapes and vegetation communities of conservation concern.

Keystone would, if permitted, restore topsoil, slopes, contours, and drainage patterns to preconstruction conditions as practicable and to reseed disturbed areas to restore vegetation cover, prevent erosion, and control noxious weeds. Because disturbed prairie areas are difficult to restore to existing (pre-disturbance) conditions, Keystone would, if permitted, use specific best management practices and procedures to minimize and mitigate the potential impacts to native prairie areas and coordinate with appropriate agencies as necessary to monitor progress.


Potential impacts to wildlife associated with construction of the proposed Project could include:

  • Habitat loss, alteration, and fragmentation;
  • Direct mortality during construction and operation (e.g., vehicle collisions, power line/power pole collisions, etc.);
  • Indirect mortality because of stress or avoidance of feeding due to exposure to construction and operations noise, low-level helicopter or airplane monitoring over flights, and from increased human activity;
  • Reduced breeding success from exposure to construction and operations noise and from increased human activity;
  • Reduced survival or reproduction due to decreased availability of edible plants, reduced cover, and increased exotics and invasive; and
  • Increased predation (i.e., nest parasitism, creation of predator travel corridors, and poaching).

To reduce potential construction and operations related effects where habitat is crossed, Keystone would, if permitted, implement measures to minimize adverse effects to wildlife habitats, including shelterbelts, windbreaks, and living snow fences.  Pipeline construction would be conducted in accordance with required permits.


The proposed route would cross rivers and streams, including perennial streams that support recreational or commercial fisheries.  Most potential impacts to fisheries resources would occur during construction and would be temporary or short term.  Potential impacts from construction of stream crossings include siltation, sedimentation, bank erosion, sediment deposition, short-term delays in movements of fish, and transport and spread of aquatic invasive animals and plants.  Keystone would, if permitted, minimize vehicle contact with surface waters and clean equipment to prevent transportation of aquatic invasive animals and plants.

Most streams would be crossed using one of several open-cut (trenching) methods. Most stream crossings would be completed in less than 2 days, grading and disturbance to waterbody banks would be minimized, and crossings would be timed to avoid sensitive spawning periods, such that resulting steam bed disturbance and sediment impacts would be temporary and minimized.

Most large rivers would be crossed using HDD methods, which would install the pipeline well below the active river bed.  As a result, direct disturbance to the river bed, fish, aquatic animals and plants, and river banks would be avoided.  If permitted, Keystone has agreed to develop site-specific contingency plans to address unintended releases of drilling fluids that include preventative measures and a spill response plan.


Construction of the proposed Project would disturb approximately 15,427 acres of land.  Approximately 90 percent of that land is privately owned while the remaining is owned by federal, state, or local governments.  Rangeland (approximately 9,695 acres) and agriculture (approximately 4,975 acres) comprise the vast majority of land use types that would be affected by construction.

After construction, approximately 5,569 acres would be retained within permanent easements or acquired for operation of the proposed Project; this includes the pipeline ROW and aboveground facilities. Nearly all agricultural land and rangeland along the ROW would be allowed to return to production with little impact on production levels in the long term.  However, there would be restrictions on growing woody vegetation and installing structures within the 50-foot-wide permanent ROW.  Keystone has agreed to compensate landowners for crop losses on a case-by-case basis.

Keystone would if permitted use construction measures designed to reduce impacts to existing land uses such as topsoil protection, avoiding interference with irrigation systems, repairing or restoring drain tiles, assisting with livestock access and safety, and restoring disturbed areas with custom native seed mixes.


Dust and emissions from construction equipment would impact air quality.  Construction emissions typically would be localized, intermittent, and temporary since proposed pipeline construction would move through an area relatively quickly.  Mitigation measures would be employed and enforced by an environmental inspector assigned to each construction spread.

All pump stations would be electrically powered by local utility providers.  As a result, during normal operation there would be only minor emissions from valves and pumping equipment at the pump stations.  The proposed Project would not be expected to cause or contribute to a violation of any federal, state, or local air quality standards, and it would not require a Clean Air Act Title V operating permit.

Construction activities would result in intermittent, temporary, and localized increases in noise levels. To reduce construction noise impacts, Keystone would, if permitted, limit the hours during which activities with high-decibel noise levels are conducted in residential areas, require noise mitigation procedures, monitor sound levels, and develop site-specific mitigation plans to comply with regulations.


The proposed Project route would cross various private, state, and federal lands in Montana, South Dakota, and Nebraska where cultural resources would be encountered.  Literature searches were conducted to locate previously identified cultural resources within the designated area of potential effects.  Field studies were conducted between 2008 and 2013 to identify cultural resources and assess archaeological resources (i.e., sites), historic resources (i.e., buildings, structures, objects, and districts), and properties of religious and cultural significance, including traditional cultural properties.  As of December 2013, most of the proposed Project area has been surveyed for cultural resources. The proposed Project area of potential effects is approximately 39,500 acres, of which approximately 1,038 acres remain un-surveyed and are the subject of ongoing field studies.

As part of this Supplemental EIS route evaluation process, consistent with the National Historic Preservation Act, the Programmatic Agreement (PA) that was signed in 2011 has been amended, finalized, and re-signed. Signatory parties to this agreement were the Department, Advisory Council on Historic Preservation, Bureau of Land Management, U.S. Army Corps of Engineers, U.S. Bureau of Reclamation, National Park Service, Western, Rural Utilities Service, Natural Resources Conservation Service, Farm Service Agency, Bureau of Indian Affairs, and the State Historic Preservation Offices of Montana, South Dakota, Nebraska, and Kansas. Invited signatories included the Montana Department of Natural Resources and Conservation, Montana Department of Environmental Quality, and Keystone. Indian tribes that participated in consultation were asked in 2013 to sign as Concurring Parties.

Pursuant to the stipulations outlined in the PA, Keystone is required to complete cultural resources surveys on all areas that would be potentially impacted by the proposed Project, make recommendations on National Register of Historic Places eligibility, provide information on potential effects of the proposed Project, and provide adequate mitigation in consultation with the Department, state and federal agencies, and Indian tribes.  Construction would not be allowed to commence on any areas of the proposed Project until these stipulations are met.  The PA, therefore, would ensure that appropriate consultation procedures are followed and that cultural resources surveys would be completed prior to construction. If unanticipated cultural materials or human remains were encountered during the construction phase of the proposed Project, Keystone would implement Unanticipated Discovery Plans pursuant to the PA.


Here is a brief description of other potential impacts:

12.1      Flood Plains:

The proposed pipeline would cross mapped and unmapped floodplains in Montana, South Dakota, and Nebraska. In floodplain areas adjacent to waterbody crossings, contours would be restored to as close to previously existing contours as practical, and the disturbed area would be re-vegetated during construction of the ROW in accordance with the CMRP.  After construction, the proposed pipeline would not obstruct flows over designated floodplains, and any changes to topography would be minimal and thus would not affect local flood elevations.

12.2     Groundwater:

The primary source of groundwater impacts from the proposed Project would be potential releases of petroleum during pipeline operation and, to a lesser extent, from fuel spills from equipment.  Any petroleum releases from construction or operation could potentially impact groundwater where the overlying soils are permeable and/or the depth to groundwater is shallow.

12.3      Wetlands:

The proposed Project would affect approximately 383 acres of wetlands. Potential impacts include:

  • Impacts to wetland functions and values;
  • Conversion from one wetland type to another; and
  • Permanent loss of wetlands due to fill for permanent project-related facilities.

An estimated 2 acres of permanent wetland loss is anticipated. Remaining wetlands affected by the proposed Project would remain as functioning wetlands, provided that impact minimization and restoration efforts described in the CMRP are successful.

13.  Cumulative Effects:

The cumulative effects analysis evaluates the way that the proposed Project’s impacts interact with the impact of other past, present, or reasonably foreseeable future actions or projects. The goal of the cumulative impacts analysis is to identify situations where sets of comparatively small individual impacts, taken together, constitute a larger collective impact.

Cumulative impacts associated with the proposed Project and connected actions vary among individual environmental resources and locations. Generally, where long-term or permanent impacts from the proposed Project are absent, the potential for additive cumulative effects with other past, present, and reasonably foreseeable future projects is negligible.

Keystone’s CMRP and planned mitigation measures, individual federal and state agency permitting conditions, and/or existing laws and regulations would, if permitted, work to control potential impacts and reduce the proposed Project’s contribution to cumulative effects.

Here is the link to Potential Safety of Pipelines – Part 3


  1. Belfer Center – Obama’s Dilemma;
  2. Executive Summary – Final Environmental Impact Statement for the proposed Keystone XL Project;
  3. Wikipedia – Keystone Pipeline;
  4. Trans Canada;
  5. Harvard Kennedy School) Belfer Center – The Next Revolution;
  6. About Tar Sands;
  7. Oil Sands Truth;
  8. Zintro – Examples of Oil Sands Experts/Vendors; and
  9. Oil Sands Truth – Shut Down the Tar Sands.