Friday, May 10, 2013

MCAS Comments on Proposed Keystone XL Pipeline Project Draft Supplemental EIS

The Honorable John Kerry
U.S. Department of State
2201 C Street, N.W.
Washington, DC 20520

April 20, 2013

Re: Comments on Proposed Keystone XL Pipeline Project
Draft Supplemental Environmental Impact Statement

Dear Secretary Kerry,

The Morro Coast Audubon Society, MCAS, appreciates this opportunity to submit comments in response to the Draft Supplemental Environmental Impact Statement for the proposed Keystone XL Pipeline Project.

The proposed pipeline project conflicts with the MCAS Mission Statement – “to promote the appreciation, conservation, and restoration of ecosystems focusing on the biological diversity of birds, other wildlife, and their habitats.”

MCAS is concerned about the development of the Keystone XL Project for a number of reasons. The lengthy laundry list of risks from climate change, to effects on our water, health, and wildlife seem to add up to a project that is “all risk and little reward”.

Red-Flags of Transporting Tar Sands Crude

Tar sands crude is the dirtiest, most dangerous oil on the planet. Not only can it create significantly greater carbon pollution than conventional oil, it is also highly corrosive and toxic.

When pipelines do rupture, it is nearly impossible to clean up – (1 billion dollar clean-up effort ongoing from Enbridge pipeline spill on Kalamazoo River on July 2010).

The U.S. Department of State points out that spills from the Keystone XL are likely to happen, estimating that there could be as many as 100 spills over the course of the pipeline lifespan.

We are now finding out that oil spills are not avoidable, preventable, or unlikely. This was especially evident the last week of March, 2013 when the Exxon Pegasus pipeline ruptured spilling hundreds of thousands of gallons of tar sands crude in Mayflower, Arkansas. Three days earlier a train derailment in Minnesota spilled 30,000 gallons of tar sands crude. These two incidents should awaken us all to the real dangers of transporting tar sands crude.

In the light of these recent tar sands oil spills, we believe it is imperative that Keystone produce site specific Spill Prevention and Containment Plans for every contingency, community, and significant resource along the entire proposed route of the pipeline.

We must ask ourselves, is it in our nation’s best interest to pipe toxic tar sands crude across American fields, prairies, and waterways? It is becoming clear that the Keystone XL is a pipeline through the United States – not to the United States. Much of the oil that would flow through this pipeline is bound for export on the global market – an export pipeline does not support U.S. energy policy.

Effects on Wildlife

Actual and complete resource impacts cannot be determined until fieldwork is collected. Because we believe this is lacking in the current draft review, we ask that a field survey review be conducted, at all project routes, for rare species of wildlife and plants to insure adequate review of the project can be performed in full compliance with the Endangered Species Act.

MCAS is also particularly concerned with the effect tar sands refinement and pipeline project may have on waterfowl and songbirds, as American migratory birds will pay a hefty price for the development of Canadian tar sands.

Birds from all four major flyways in North America converge in the Canadian boreal forest and the Peace-Athabasca Delta region in northeastern Alberta. Virtually every facet of tar sands oil development has the potential to harm boreal birds, many of which are migrating and are protected by treaty and national law.

Each spring more than half of America’s birds flock to the Canadian boreal forest to nest with anywhere from 22 to 170 million migratory birds breeding each year in the 35 million acres of boreal forest that may be destroyed by tar sands oil development.

According to “Danger in the Nursery” – the National Resources Defense Council report on the tar sands impact on birds. . .”the cumulative impact to developing the Canadian tar sands over the next 30-50 years could be as high as 166 million birds lost, including future generations.”

Of the millions of birds that could be lost by tar sands development, a large number are species of known conservation concern. The Whooping Crane, a critically endangered species currently numbering around 400 individuals, concludes its annual migration directly northwest of the tar sands. The strip mines, fragmented forests, and the 70 square miles of toxic tailings ponds, which appear inviting to the whooping cranes from the air, lie directly on their migration route.

Toxic Tailings Ponds

Tar sands open-pit mining pollutes vast amounts of water that end up in massive toxic tailings ponds. These ponds are so large they can be seen from space. In the spring, when most natural water surfaces are still frozen, tailings ponds are often the only source of open water. Waterfowl that land in these ponds are soon slick with toxic oil – in 2008, at one Alberta tailings pond, 500 ducks died within hours of landing in the toxic water. The toxic chemical concentration is so high in these ponds that some companies hire workers to rake dead birds from the surface.

Tailings pond bird deaths may be just the tip of the iceberg as habitat degradation and loss are likely a much larger threat to America’s birds. The Keystone XL Pipeline Project will increase the extraction of Canadian tar sands and therefore increase greenhouse gasses – while at the same time remove the carbon sequestering boreal forest . . . a double blow for migratory birds struggling to adapt to climate change.

MCAS urges the State Department to include the harmful effects from tar sands development on birds and their habitat in their final environmental review.


The Keystone XL is more than just a pipeline project; it is a reflection of the lack of commitment to battle climate change. This administration has made strong statements regarding climate change, but actions speak louder than words. We believe that it is insincere to argue that the progression of this project has our nation’s best interests in mind. Supporting a technology that will unlock vast amounts of additional carbon that we cannot afford to burn, extends our addiction to fossil fuels, fragments and destroys important wildlife habitat, and places critical water resources at risk is backward thinking and contrary to sound environmental and climate policy.

We urge the Secretary of State to ensure that the State Department, and this administration, have a full understanding of the climate and environmental impacts of this project – which we believe are glossed over and inadequate in the current draft review.

Respectively submitted,

Douglas W. Tait

Doug Tait, Conservation Chair

Morro Coast Audubon Society