Kearl Module Transport Project EA

Comments of the National Wildlife Federation on the Kearl Module Transport Project EA

05-13-2010 // Tom France, Regional Executive Director

Dear MDT:

These are the comments of the National Wildlife Federation on the above-referenced project.

The National Wildlife Federation was founded in 1936 as the national voice of state and local conservation groups, and has since emerged as the nation's foremost grassroots conservation organization, leading a dedicated network of members, supporters and 48 affiliated organizations throughout the United States and its territories.

This office strongly objects to the proposed project and to the adequacy of the Environmental Assessment (EA). We have not only reviewed the EA, but also two of our staff attended the hearing at the Meadow Hill Middle School in Missoula on April 29. We are dismayed by the narrow scope of issues MDOT is using to evaluate this project. In response to questions, the representatives of Exxon and Jim Lynch of MDOT dismissed altogether suggestions that the EA was an insufficient response to the serious environmental issues left unaddressed and to the absence of consideration of societal problems associated with facilitation of the development of petroleum production for Canadian tar sand oil fields. There are far more serious issues at stake than a 32-J permit from MDOT for an over-dimensional load transportation permit and these impacts must be evaluated.

The most serious of these considerations involves whether the State of Montana should be complicit in this Canadian development project because of the impact the project will have on the global environment. There is no more serious issue facing society, than finding ways to limit and reduce the concentration of greenhouse gases in the Earth’s atmosphere. These threats were fully explored in the 4th Intergovernmental Panel on Climate Change (IPCC) 2007 report. In light of the devastating consequences of failure to deal with greenhouse gas emissions, MDOT’s concentration on the concerns discussed in the EA is far worse than fiddling while Rome burns; it is fiddling while the planet fries.

The Exxon representatives at the meeting asserted that all these climatic concerns were considered when the Canadian Provinces finalized their development proposal and that the only issue left on the table was the transportation issues. We completely reject their suggestion that US and Montana laws, and long-range environmental concerns, regarding the development project are not valid considerations because the Canadian Provinces have made their decision. It is in our global, national, state, and individual interests to find ways to reduce emissions of carbon into the atmosphere. However, developments like this one, which has a huge carbon footprint for each gallon of petroleum produced, goes in the opposite direction. We should insist on a complete US Environmental Impact Statement (EIS) to assure that this full range of issues is addressed from a larger perspective than it has been thus far.

The EA leaves open for discussion only the narrow engineering and social issues associated with transporting this equipment and completely takes off the table of whether society should be enabling this kind of development. The self-interest of the developers is clear and has been heard. The self interests of the citizens of Montana need to be heard, as well.

In addition to this broad consideration of the need for an EIS, there is also justification for requiring an EIS based on threats to endangered or threatened species during passage of this equipment through Montana, Idaho, and Oregon. Assertions that such threats are minimal mirror those made by developers of offshore oil drilling platforms like the one now spilling 5,000 barrels of oil per day into the Gulf of Mexico. On a more local basis, the likelihood of accidents to trucks using Highway 35 around Flathead Lake were also dismissed by MDOT, but we have learned that accidents can, and have, happen that have serious consequences regarding water purity and wildlife considerations.

The EA rejects alternative routes across Canada because these all have restrictions without possible detours and were, therefore, considered to be infeasible. The restriction for the Highway 16 route is a bridge with a height restriction about 35 miles east of Prince Rupert. This restriction may be financially infeasible from Exxon’s standpoint, but that does not make it generally unfeasible as another bridge could be built. The same is true for the height restriction of an overpass over Highway 1, which is 90 miles east of Vancouver. Modifications to, or detours around, this overpass seem physically feasible and we are not convinced by Exxon’s desire to take these off the table for financial reasons. MDOT should not approve a project just because the Canadian routes would cost the Canadians more. Correspondingly, we believe the draft EA does not comply with the MEPA requirement that “realistic and technologically available” alternatives to the proposed action be considered.

We also believe the EA is deficient in its analysis of the cumulative environmental impacts of creating a new High/Wide corridor along the proposed route. This needs to be considered because it is highly likely that once the infrastructure is in place, that the route will become a permanent or frequent corridor for transportation of High/Wide loads through Montana. The EA fails to examine the “…secondary and cumulative impacts” as required by MEPA.

Finally, we found no documentation in the EA about reimbursement to the State of Montana for the costs of preparing the EA. We note that Table 18 (Estimated Value of Environmental Permitting to Montana) appears to indicate that these costs totaled $1.1 million. It may be that the contractors will reimburse the state for these costs, but we could not find where this was explicitly stated.

Thank you for your consideration of these comments.

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