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Today is the last day to provide comments to the Department of State as to the KeystoneXL pipeline national interest determination.

The reviewers of public comments -- if they take their work seriously and responsibly -- have a lot of work ahead of them.  While there are some 54,897 comments, already registered as of the time of this blog post, citizens' groups are planning to deliver millions to the Department of State in a few minutes.

To date, I have posted three comments which are reposted after the fold.

While I had been planning comments, several of these were inspired by James Well's admonition to 'make it personal, because it is'.

These comments are each unique and they take three different angles:

  1. Highlighting the need to look at this within the larger context of our necessity to stop investing in fossil fuel (fossil foolish) infrastructure.
  2. Laying out how Keystone XL will not serve U.S. national interests; and
  3. Connecting Keystone XL back to me as an individual, with individual expertise, and expertise ... and children that I care about.

I hope you find the comments interesting, valuable, and even inspiring to get you to add your voice.

Keystone Comment #1: Why is local planning relevant to national decision-making? Or, STOP MAKING IT WORSE!

American governance -- from local governments through states to the Federal government -- has a problem: we see and review programs and situations through stovepipes.

This became clear to me in a local permitting situation over 15 years ago. Within two miles of my home, there were over a dozen projects that were before the planning board. For every single one of these, the planning board told the political decision makers that the project 'would have no meaningful impact on traffic' and thus there was no requirement to do any transportation improvements. While no specific project would add more than 100 cars to the morning/evening rush hour, the 12 projects together were forecasted at that time to add more than 500 vehicles. (And, well, another point is that the analysis was faulty: one development of 130 million dollar homes was said to be adding only 20 cars to morning/evening rush hour as 'the owners would walk to work' (nearest offices about a mile away ...) -- actual figures have been over 150 ...) When I asked the planning commission staff about the impact of 500 cars, they told me that 'this will hurt the traffic situation and we should add lights and some turn lanes' but (BUT) they were prohibited from analyzing aggregate impacts for decisions about any specific project.

Keystone XL is a quite similar circumstance.

President Obama has stated a threshold for approval: whether it will "significantly" contribute to worsening climate change. Now, of course, "significantly" can (and does) mean different things to different people. The real problem is that we cannot and should not be viewing this one (HUGE) project in isolation.

We face a simple reality: we must move away from our current polluting energy economy and toward a cleaner, sustainable, and more prosperous economy.

Every dollar, every penny, every worker hour that we -- as a nation and society -- invest in increased fossil fuel infrastructure means resources taken away from creating the clean energy future.

While KeystoneXL is not a sensible project on its own merits (it will raise American gas prices, foster increased tar sands production, end up having a net negative impact on American employment due to those increased fuel prices, ...), it is an incredibly important and tangible choice about our collective future: Will we put the pedal to the metal and hurtle off the climate cliff like Thelma and Louise or are we serious about creating a more secure, prosperous, and climate friendly future for the United States and its (born and yet-to-born) citizens?

Keystone XL decision making is a moral referendum on our willingness to do the simplest thing we must do to avert catastrophic climate disruption: Stop making it worse.

Specifically and categorically, we must cease making large, long-term capital investments in new fossil fuel infrastructure that “locks in” dangerous emission levels for many decades.

Keystone XL is not in the U.S. National Interest on its own and certainly not in our interest when taken out of a stove-piped look and considered with the broader context of what we must do to avert catastrophic climate chaos.

Keystone Comment #2:  "Why Not KXL, let me list the reasons ..."
The KeystoneXL pipeline is simply not in the U.S. national interest and should not be approved.

Here are core basic points as to 'why not' Keystone XL:

Keystone XL will:

* Increase climate risks by enabling increased production of dirty tar sands (both through the fuels' carbon content and damage to the boreal forests' ability to retain carbon)

* Worsen environmental damage in Alberta, CA, due to increased tar sands exploitation

* Increase gasoline and diesel prices for most Americans

* Hurt American economic competitiveness (due to increased pressure on US fuel prices and lower pressure on world oil prices)

* Have serious health impacts on people living in the United States

* Undermine our path to a clean-energy future

* Undermine and discredit any U.S. efforts to lead on climate change issues internationally

On the other hand, KeystoneXL will NOT reduce America's dependence on foreign oil, will NOT lead to net job creation, will NOT improve international security, will NOT improve our energy security, will NOT serve American nor Americans' interests.

Keystone XL Comment #3:  Making it personal
I am an American citizen, taxpayer, voter desirous of well-run government.

I am a patriot, who has volunteered for and served in multiple hazardous zones in support of national objectives, having shown my willingness -- on multiple occasions -- to risk my life to help secure the nation.

I am a parent, with three children, hoping for a future where they will have a chance to succeed and thrive.

I am an analyst, able to understand situations from multiple dimensions, hopeful that thoughtful and honest analysis supports decision-making in a well-run government that working to secure the nation and create a prosperous future where my (and all American) children have the best environment to create their own successes.

I am -- with these in mind -- passionately opposed to KeystoneXL approval.

Keystone XL approval would be BAD GOVERNANCE

To date -- the Keystone XL review process has been riddled with questionable activity, such as contractor dishonest on conflict of interest statements and misalignment of the review process with the national objectives for greenhouse gas emission reductions. Questionable ethics -- if not outright illegality -- have riddled the process.


Climate Change represents the most serious risk for the future prospects for humanity -- which includes, not least for me, my children's future prospects. Unmitigated climate change will drive rising seas (threatening not just beach resorts but massively important economic infrastructure and ecosystems around the world), disrupt agricultural systems, make parts of the world essentially uninhabitable compared to today, foster increasing weather whiplash, and ... Keystone XL will foster increased tar sands production and add a tangible -- a significant -- amount of carbon pollution.

Keystone XL approval would be based on BAD ANALYSIS

The Department of State reviews have serious analytical flaws. These include:

* Use of a marginal cost for additional Tar Sands production of $45 per barrel rather than the accepted industry figure of $60 per barrel. That $15 dollar difference is critical for understanding how Keystone XL will -- contrary to the report's conclusion -- facilitate greatly expanded Tar Sands production and thus "contribute significantly to worsening climate change".

* Using "Business as Usual" (BAU) Energy Information Administration (EIA) figures for looking at carbon implications when those EIA BAU scenarios (a) guarantee climate catastrophe with temperature increases far above 2 degrees centigrade and (b) are at odds with the President's stated objectives for reducing carbon emissions by 17 percent by 2020.

In the analytical world, there is a standard joke: "Lies, Damned Lies, and Statistics". In this case, we perhaps need to add a fourth category: "Oil-Industry Provided Statistics Used By the Department of State in the Keystone XL Review".

Simply put: Keystone XL approval would be a catastrophic step in the wrong direction.

As a patriotic citizen, I have substantive reasons to oppose Keystone XL pipeline.

As an experienced energy analyst, I have substantive reasons to oppose the Keystone XL pipeline.

As a loving parent, I have substantive reasons to oppose the Keystone XL pipeline.

9:11 AM PT: For the press release from the delivery of 2 million comments to the State Department, see here: (bottom of post)

Originally posted to Climate Change SOS on Fri Mar 07, 2014 at 08:42 AM PST.

Also republished by Climate Hawks, DK GreenRoots, and Kitchen Table Kibitzing.

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