This point, of course, is not one that should sway the Department of State analysis of the project … but it should impassion you to add your voice to the discussion.
XL Pipeline “Public Comments”
Let your voice be heard by opposing the Keystone XL Pipeline.
The deadline for submission of comments is March 7, 2014.
Writing public comments in opposition to the presidential permit for the Keystone XL pipeline is easy. This is your opportunity to make your voice heard directly to the White House without interference by the media, lobbyists or the GOP. We have until March 7 to express our views on whether or not building the big tar sands pipeline is in the vital national interest of the United States.
In the past, public comments have absolutely made a difference. Please don’t delay as it is the last opportunity to affect this public debate. Submit your comments today … http://www.regulations.gov/#!documentDetail;D=DOS-2014-0003-0001].
For more helpful tips, please consult ["Tips for Submitting Effective Comments" http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf] at [regulations.gov http://www.regulations.gov/#!documentDetail;D=DOS-2014-0003-0001], the website where you will be posting your comments. A
All of us should add our voices to the State Department comment period.
After the fold is an overview of some of the reasons and arguments that you might choose to make.
Today, some 400 university students were arrested at the White House. These students are a leading wave of what could be the largest civil disobedience movement in the United States in decades. Echoing the over 1200 arrested two summers ago, also at the White House fence, these 400 — and the thousands who marched from Georgetown to the White House with them — have a simple message to President Barack Obama:
Live up to your rhetoric on climate change.
Deny the Keystone XL pipeline due to its detrimental implications for fostering catastrophic climate chaos.
Put the U.S. — and us — on a path toward climate solutions.
Let us be clear, the decision as to Keystone XL pipeline is not ‘it’ on climate issues. If every other fossil foolish project proceeds, the United States keeps promoting coal exports, and there are not a myriad of other shifts for the better globally, approving Keystone XL will only be slight additional pressure on the gas pedal as we hurtle over the climate cliff. Keystone XL is significant only if we have any seriousness about averting catastrophic climate chaos. Denying Keystone XL will be a statement that President Obama is not interested in emulating Thelma and Louise — that he is serious about putting an end to the United States of Petroleum even when facing pressure from the Petro State to the north to foster greater exploitation of the Tar Sands climate bomb.
These 400 could represent the first of many to come. Facing a ethically (if not outright) corrupt State Department review process, Americans of all colors, races, creeds, economic status, ages, and communities have committed themselves — as part of XLDissent — to follow the 400 into the breach in the call for climate sanity.
Climate change has many faces — weather whiplash is one. Yet again this winter, the Washington, DC, area is going to see a rapid 30+ degree shift in temperature. The 400 arrived at the White House in temperatures hovering around 60. By tomorrow, at this time, the White House should be bathed in white — with many inches of snow and ice. This is a signal of climate chaos reality just as the 400 arrested are a signal calling for sanity when it comes to Keystone XL.
President Obama has said some strong words as to climate change. He has ordered Administration action that will reduce carbon pollution and shift us from ‘business as usual’ toward lesser carbon emissions. The Keystone XL decision is his — this is an action that he can, and should, take to signal that it is no longer ‘business as usual’ and that we will fight to create a prosperous, climate-friendly future for America.
With that in mind, valuable thinking and substance in the post that follows.
In the comment section of the EnergyCollective, I saw the same myth that I have seen time and time again regarding wind power:
Fact 1: renewables are aleatorically intermittent, and so unreliable.Fact 2: due to Fact 1, they cannot provide energy when it is needed, but only when and in the quantity they can
Fact 3: users have to get energy when they need it, not when it is aleatorically provided
Fact 4: to date, there is no storage system that can be useful for a complex industrial society
Fact 5: due to facts 1 to 4, renewables need to have a back up system that can cope with the needs of the users.
Fact 6: that back up system cannot be just stopped and then put to generation in a few seconds or minutes, and usually have to generate at low efficiency to maintain the back up at call point, generating added costs, besides the usuals as maintenance, lost profits, complex distribution grid, etc.
… not surprisingly ending with climate crisis denialism in “Fact” 8, since the name of the game here is clearly not arguing by starting with facts and seeing what conclusion you arrive it, but rather is myth creation and propagation in support of an already selected conclusion.
While many people don’t know what “aleatorically” means, many would actually share the misconception that windpower is an intrinsically intermittent resource. However, for wind power, the “Fact 1″ is in many cases “Falsehood 1″. Even though individual wind turbines are intermittent, for many wind resource regions, it turns out that a substantial share of wind power is not intermittent at all, in either their “by chance (aleatorically) and unpredictable” component or their “by chance (aleatorically), though predictable” component.
Reading the latest editorial by Marcia McNutt, the editor of Science magazine, makes one wonder: Does she understand and have any respect for ‘the Dismal Science‘? Very simply, McNutt failed to demonstrate basic knowledge about economics (that ‘dismal science’) and failed to consider basic business calculations (and ignored many other reasons why Keystone XL is not in the US national interest) in what is thus a flawed argument in favor of the Keystone XL pipeline.
To be clear, counter to McNutt’s erroneous assertions:
Building Keystone XL will accelerate and expand the exploitations of Tar Sands and, therefore,
Keystone XL pipeline will lead to increased greenhouse gas emissions (and other environmental damage).
The science of climate change is leaping out at us like a scene from a 3-D movie. …
Terrorism, epidemics, poverty, the proliferation of weapons of mass destruction, all challenges that know no borders. The reality is that climate change ranks right up there with every single one of them.
Secretary Kerry called on citizens — worldwide — to call on leadership to lead on climate change.
Secretary Kerry also commented about disinformation, including disinformation about cost-benefit analysis related to climate change mitigation:
We shouldn’t allow a tiny minority of shoddy scientists and science and extreme ideologues to compete with scientific fact, nor should we allow any room for those who think that the costs associated with doing the right thing outweigh the benefits.
There are people who say, “Oh, it’s too expensive, we can’t do this.” No. No, folks.
Secretary Kerry continued to highlight that the costs of inaction are too high:
President Obama and I believe very deeply that we do not have time for a meeting anywhere of the Flat Earth Society. One of the arguments that we do hear is that it’s going to be too expensive to be able to address climate change. I have to tell you, that assertion could not be less grounded in fact. In fact, it’s exactly the opposite. Serious analysts understand that the costs of doing nothing far outweigh the costs of investing in solutions now. You do not need a degree in economics or a graduate degree in business in order to understand that the cost of flooding, the cost of drought, the cost of famine, the cost of health care, the cost of addressing this challenge is simply far less – the costs of addressing this challenge are far less than the costs of doing nothing. Just look at the most recent analysis done by the World Bank, which estimates that by 2050, losses – excuse me one second – losses from flood damage in Asian ports – fishing ports, shipping ports – the losses in those ports alone could exceed $1 trillion annually unless we make big changes to the infrastructure of those ports.
Most people look at the challenge of climate change and they think, my goodness, it’s going to be costly.
Well, it turns out that, just as the science is firming up, so too the economics is firming up.
It turns out that if we do it right, we can have a transition to a low carbon future that actually has more jobs, more technology and actually benefits people.
This is a critical point: our economic system will be more fruitful (in the near, mid, and long-term) for all  if we pursue a low-carbon future due to better job creation, better living standards, better health, better education, better …, and, oh by the way, reduced risk from catastrophic climate chaos.
Sadly, the global discussion is dominated by ‘it will cost to take action to mitigate climate change’ rather that assessing, embracing, and educating the truth that smart mitigation policies will strengthen economies while reducing climate change risks and costs.
the New Climate Economy project, bringing together some of the world’s foremost economic experts to examine how stronger economic performance can be supported by good climate policy. The project aims to contribute to the global debate about economic policy, and to inform government, business and investment decisions.
“Climate impacts are rising and the evidence of warming is increasingly clear, but most economic analysis still does not properly factor in the increasing risks of climate change or the potential benefits of acting on it,” said Commission Chair and former President of Mexico Felipe Calderón. “We need urgently to identify how we can achieve economic growth and job creation while also reducing emissions and tackling climate change.” ….
“At a time when governments throughout the world are struggling to boost growth, increase access to energy, and improve food security, it is essential that the full costs and benefits of climate policies are more clearly understood,” said Lord Nicholas Stern, Vice-Chair of the Commission and author of the 2006 Stern Review. “It cannot be a case of either achieving growth or tackling global warming. It must be both.”
While there are those who strongly dismiss the potential for ‘green capitalism’ , a fundamental truth is that sensible climate mitigation policy offers the potential for accommodating improved human living conditions (improved economic performance) while offering a potential for avoiding utter catastrophic climate chaos.
Secretary Kerry - and others who understand the critical need for climate mitigation policy and investments — would be well served to pay attention to The New Climate Economy Project.
 Of course, “all” is not a fully true term. Those heavily invested in fossil fuel (foolish foolish) endeavors will not necessarily see the economic benefits that the vast majority of humanity and economies will reap from sensible climate policy. However, we should explicitly recognize that these businesses, individuals, institutions, nations, etc are privatizing profits (to themselves) while socializing costs (pollution costs — health, climate, etc …) to all.
When it comes to climate mitigation opportunities, there is a simple reality:
Benefits outweigh costs … enormously.
And, when it comes to climate mitigation and adaptation investments, we should be striving to achieve multiple wins from the same action wherever and whenever possible.
When looking at President Obama’s announcement, this morning, of new truck energy efficiency standards, it is clear that the measure meets the criteria of multiple wins. The fact sheet (see after the fold) title clearly points to this:
Opportunity For All: Improving the Fuel Efficiency of American Trucks – Bolstering Energy Security, Cutting Carbon Pollution, Saving Money and Supporting Manufacturing Innovation
improving gas mileage for these trucks are going to drive down our oil imports even further. That reduces carbon pollution even more, cuts down on businesses’ fuel costs, which should pay off in lower prices for consumers. So it’s not just a win-win, it’s a win-win-win. You’ve got three wins.
Looking at the fact sheet, there is a quadruple win space laid out:
Energy efficient vehicles lower the nation’s vulnerability to unstable global oil markets ;
Reduced fuel use, by definition, will contributing to lowering greenhouse gas emissions (compared to a business-as-usual case);
The upfront investment in more efficient vehicles will be more than compensated for in reduced fuel costs; and,
The drive for more efficient trucks, as is happening with automobiles, will spur innovation and increase American competitiveness.
This quadruple win actually significantly understates the full value streams as this move is actually a W6: a Win to the Sixth Power climate mitigation action.
As we strive to stop digging the holes deeper and climb our way out, we can seek to deal with these challenges in a stove-piped manner or address them with W6 solutions that have wins across multiple arenas:
Support energy independence
Create and protect jobs
Foster economic activity (cost effectively)
Strengthen long-term economic prospects
Address negative environmental impacts (from local pollution to acidification of the oceans)
Help mitigate climate change
As some are wont to say, crises create opportunities. One good piece of news, amid all the serious concerns that that list above should create for all of us, is the reality that many Win-Win-Win-Win-Win-Win (Win to the Sixth) opportunities lie before us, if we choose to seize them.
Let’s look at just a few additional value streams from the move for more fuel-efficient vehicles:
Improved health and reduced health care costs:
Diesel fumes are directly linked to numerous health problems from irritated eyes, to asthma, to cancer, to …
“Health studies show that exposure to diesel exhaust primarily affects the respiratory system and worsens asthma, allergies, bronchitis, and lung function. There is some evidence that diesel exhaust exposure can increase the risk of heart problems, premature death, and lung cancer.”
“About 70 percent of the cancer risk that the average Californian faces from breathing toxic air pollutants stems from diesel exhaust particles”. One California study found that “diesel-particle levels measured in California’s air in 2000 could cause 540 “excess” cancers (beyond what would occur if there were no diesel particles in the air) in a population of 1 million people over a 70-year lifetime.”
The National Academy of Sciences estimated in the range of $0.16 per gallon of liquid fuel burnt in health care costs (which includes, by the way, gasoline which has lower health care implications).
The White House is estimating 530 million barrels of total fuel savings. Working with the NAS figure, $0.16 per gallon, this translates to $6.72 per barrel or roughly $3.6 billion in health care benefits.
The improved fuel efficiency is an investment — an investment in ‘capital’ value. That additional upfront investment translates into work in design facilities to get to the improved vehicles and in factory jobs to build better trucks.
Reduced fuel prices
Very basic economic principle: the law of supply and demand. Reduced demand leads to lower prices. Lowering US oil demand by 1 million barrels per day will, by definition, foster lower prices than what might have been the case with greater demand. If this is $2.50 per barrel and total US oil use were 15 million barrels per day, then this would have roughly $10 billion in reduced crude oil costs.
Even amid booming U.S. oil production, there is a simple reality: the United States imports oil. Reduced oil demand translates directly to an improved balance-of-payments as every barrel of oil saved is, nowadays, roughly $100 less of import costs.
Improved trucking efficiency
Simply put, keeping all other factors the same, a more energy efficient system will have other efficiency benefits that build on the fuel efficiency. For truckers, this will mean greater flexibility as to when and where to refuel as they will not have to refuel as often.
In his speech today, President Obama highlighted that this is a “win-win-win” opportunity. In fact, the President and the White House press release left out many wins from the discussion.
PS: As an aside, far better would be to invest in Steel Interstates and to reduce the need for trucking. See, for example,
For those who have been following the process, the conclusions of the updated Department of State Environmental Impact Statement “analysis” are of little surprise, since they basically repeat the previous conclusion before the analysts ~ analysts connected to the oil industry, since, of course, they would know about this kind of stuff ~ were told to repeat the analysis. That is, to quote part of the Think Progress Coverage:
The newly-released report admits to the obvious: that â??the total direct and indirect emissionsâ? of the project â??would contribute to cumulative global GHG emissions.â? But in its final analysis, it says the proposed pipeline is â??unlikely to significantly affect the rate of extraction in oil sands areas,â? and does not look at the overall greenhouse gas emissions of the tar sands oil that would flow through it.
The underlying, unstated, premise of the entire environmental and economic impact is that we will in any event produce a large portion of the tar sands that are in the ground. And that implies, of course, that we are screwed: we have to adopt policies keep 80% of existing reserves of carbon based fossil fuels in the ground in order to have a prospect of keeping global warming under about three and a half degrees Fahrenheit and have at least some chance of avoiding the kind of catastrophic climate change that will eliminate the United States as a single national society and economy.So the analysis, including unstated premise, is: “Assuming that the nations of the world do not impose adequate policies to avoid a catastrophe with costs that dwarf the entire presumed value of the tar sands deposits, this is the impact of building or not building the Keystone XL pipeline.”
But, what is the impact of building or not building the Keystone XL pipeline presuming that we doadopt policies that are adequate to keep 80% or more of current existing fossil fuel reserves in the ground? The analysis avoids that question entirely, even though the analysis delivers the numbers that allows use to evaluate those costs.
In the letter (in entirety after the fold), Steyer calls for an “independent and transparent review” of the EIS. As a prominent example, one has to wonder how the ‘business savvy’ analysts writing the EIS come to such a radically different conclusion about the pipeline’s importance to enabling increased tar sands exploitation compared to the CEOs of the very Tar Sands-invested Corporations.
Of particular concern are FEIS conclusions that conflict with and are contradicted by tar sands industry executiveswho confirm that they need the pipeline in order to continue to develop the tar sands and to reach international markets. The FEIS fails to consider that construction of the KXL pipeline is a necessity to fully maximize extraction of tar sands.
While the State Department report essentially calls the pipeline irrelevant for investment decisions as to tar sands production, industry executive after industry executive have called it critically important.
While the report has assertion after conclusion after assertion for which there are significant and serious reasons for disagreement (and seems to dismiss and/or ignore reasons why the Keystone XL pipeline is NOT in U.S. national interest), there remains a fundamental challenge that Steyer calls on the Secretary of State to investigate and address: the entire process was tainted in such a way that makes wonder how the report could ever have been released.
Monday, 3 February, there will be #NoKXL vigils around the nation. Find an Anti-Keystone vigil near you.
And, somewhat big time … if your state isn’t represented (and 43 are, already, just from Friday), create a vigil in your state. Pretty amazing if, the business day after the late Friday release, all 50 states (plus DC) have vigils.
PS: And, there is another issue — amid a raft of contractor controversies and failures (Snowden, Affordable Health Care Act debut, Navy criminal investigations, etc …), what does the Keystone EIS say about the Department of State’s ability to contract effectively? ….
A typical Washington ploy — release late on Friday afternoon material that you hope disappears into the dustbin of weekend inattention to serious matters. The State Department’s release, earlier today, of a flawed look at the Keystone XL pipeline’s climate impact derived from a highly questionable (highly questioned with Inspector General investigations ongoing) process is a classic example. The world, however, is changed. The movement of information has changed. And, this is not something watched solely by people locked to their M-F, 9-5 jobs.
To start with, based on a quick initial read, here are a few examples of how this looks to be a flawed report?
It essentially assumes away the possibility that not building the Keystone XL pipeline would lead to reduce production of Tar Sands dilbit.
This is highly questionable.
The reason for the pipeline: to get the oil to Gulf Coast refineries so that it can be sold into Chinese and European markets at world prices, rather than depressed Midwest US prices. Taking the oil out of the US market and sending to China would create roughly $20 per barrel greater profit for the producers. (This is, of course, the absolute core reason for building the pipeline — to maximize profits for those devastating Alberta digging up tar sands.) Hmmm … according to the State Department, against the logic of basically every single economic textbook ever written, more or less profit is irrelevant for (dis)incentivizing more or less aggressive efforts to expand production. Harvard MBAs watch out — everything you learned is, evidently, wrong.
Even with rapid growth in rail transport capacity, the issue is not just price but capacity for moving dilbit out of Alberta. Keystone XL would be like opening a valve to release pressure, giving confidence to those considering Tar Sands extraction investments that they would be able to send their product to market for higher prices.
The oil industry knows and even, when honest, admits this. As per one oil industry executive: “If there were no more pipeline expansions, I would have to slow down.”
If you assume that the Dilbit will get produced and burnt no matter what you decide to do, of course the pipeline construction will not “significantly” impact climate change. The carbon will be pumped, according to this assumption, no matter what.
The report is at odds, in essence, with stated US policy on climate change.
It, in essence, uses a “business as usual” case for examining the KXL impact rather than “business as necessary”. This choice is a policy one and was not, as far as I can tell, ordained by law.
These examples of flawed (if not biased, skewed, questionable, ….) analysis are not, however, perfectly relevant for this posts’ title.
In Washington DC, information is currency. On Wall Street, information translates into massive currency.
For the past few days, key oil interests and players with, evidently, insider knowledge – such as the American Petroleum Institute’s Jack Gerard — created a buzz, telling reporters and who knows who else, that the State Department review of Keystone XL would come out Friday and that it would be favorable to the project. Hmmmm … their creation of buzz seems to have, clearly, been based on some real information.
Who in the Department of State (or elsewhere) provided this information to Gerard?
Let’s be clear — the Keystone XL pipeline is a multi-billion dollar project with tens of billions of dollars of impacts for the Tar Sands industry and other business interests. Many — probably most — of these are publicly traded firms whose business prospects and, more specifically, stock prices can be impacted (if not driven) by major government reports and decisions. Those with insider knowledge of Government decisions — able to place trades minutes, hours, or days before anyone else with that information in hand — have an unfair (hmmm, might one say illegal) advantage on Wall Street.
Consider, for a moment, some other scenarios:
Someone gained information from a source that a government report was going to recommend FDA approval of a drug with $10s of billions of potential revenue. Would they be in an advantageous — illegally advantageous — position for trading that stock?
Company executives began telling reporters, days beforehand and accurately it turns out, that the Pentagon was going to announce that their company won a major project that would double their revenue. Would it make sense for the SEC to take a look at seeing whether there was any unusual trading in the stock in the week(s) before the announcement and to look into how the company executives knew (and were stupid enough to tell people what they knew) that they had won the project prior to the announcement?
Again, in Washington, DC, information is currency. On Wall Street, information is massive currency.
Doesn’t it seem reasonable to wonder how petroleum interests had an inside track on this currency this week?