Douglas A.

Grandt

PO Box 6603 Lincoln, NE 68506 February 17, 2014

Bureau of Energy Resources, Room 4843 Attn: Keystone XL Public Comments U.S. Department of State 2201 C Street NW Washington, DC 20520 Re: TransCanada permit application for the Keystone XL pipeline Dear John Kerry and Barack Obama: I applaud the impeccable logic and conclusions of Henry Auer, Ph. D. in his comment DOS-2014-0003-4550, and would like to echo his words, as follows, for the record: Under section II. Effects of Man-Made Greenhouse Gas Emissions on Global Warming. "[Most] anthropogenic climate change is irreversible on a multi-century to millennial time scale because there is no natural process operating within this time scale that removes CO2 from the atmosphere. The warmer climate will worsen extremes of weather and climate that are already occurring, causing serious harm to people and major damage to the land." Under section III.A. Lifecycle analysis of GHG emissions omits consideration of the notransport case. "...the Final SEIS seeks to render futile the possibility that the Application will not be approved by proposing that extraction and shipment not under the control of the U. S. administration would occur regardless. This is highly improper, for it seeks to make the U. S. complicit in promoting further emissions even if the Application is not approved. No such responsibility in fact exists. The U. S., acting in accord with considerations of global environmental policy and its own national interest may indeed decide against approving the Application. Any consequences of such a decision due to actions of third parties would be beyond the scope and power of the U. S. and should not influence the decision to be made." Under section III.B. Assessment of alternative routes for oil transport belittles the no-transport case. "...the Final SEIS infers the futility of not approving the Application by strongly implying that importation will occur in any case, in ways no longer under the control of the U. S. administration. This is highly inappropriate, for it seeks to burden the U. S. government with consequences of promoting further GHG emissions even if the Application is not approved. No such attribution in fact exists. The U. S., acting in accord with its global environmental policy and its own national interest may indeed decide against approving the Application. Any consequences of such a decision due to actions of third parties would be beyond the scope and power of the U. S. and should not influence the decision to be made." Under section IV.A. Greenhouse Gas Emissions "Because of the harms brought by increasing GHG concentrations, the U. S. should be embarking on policies that avoid adding new GHGs to the atmosphere. Approving the Application would have the opposite effect, worsening global warming."

Douglas Grandt February 17, 2014

Under section IV.B. President Obamas stated policy is to reduce GHG emissions. "Approval of the Keystone XL Application would enshrine significant new GHG emissions for up to half a century or longer. This would directly contravene the Presidents pledge to honor our moral obligation to future generations to mitigate global warming. It would make it harder to attain meaningful reductions in the future." Under section IV.C. The U. S. is involved in negotiations for a worldwide pact to reduce GHG emissions. "Approval of the Application would critically jeopardize these negotiations, and would make it harder for the U. S. to attain international agreement to limit GHG emissions." Under section IV.D. Climate models show that the longer we wait to undertake abatement of emissions, the more intensive and the more expensive those efforts will be. "There is overwhelming consensus among climate scientists that humanity has to migrate from fossil fuels to renewable energy sources as early as practicable. The U.S. would promote these goals by denying the present Application." Under section IV.E. The anticipated cost of the Keystone XL pipeline, if redirected, could be used to install significant renewable energy capability. "It would be in our national interest to develop policies and practices that induce fossil fuel energy companies to invest in renewable energy sources." Under section IV.F. The Final SEIS pays short shrift to the viable option of not approving the application and investing instead in renewable energy. "As noted above, the document improperly seeks to make the U. S. government responsible for added emissions arising from alternative strategies if they are implemented by other, foreign, parties. It is inappropriate to make such an unfounded attribution." Under section V. Conclusion "This Comment has identified fundamental omissions in the DOS Final SEIS whose effect is inappropriately to suggest that failure to approve the Application would implicitly implicate the U. S. in the consequences of continued burning of WCSB oil. DOS and President Obama should resist such implications, and decide the fate of the Application purely according to the national interests of our country. "That interest lies exclusively in undertaking actions with regard to global warming that safeguard our nation and our planet from further climatic degradation. This Comment summarizes many facets in the science underlying global warming and policies that we need to undertake to address this critical problem. In general, as urged by climate scientists around the world, we should not continue policies that expand use of fossil fuels. Rather, we should develop new practices that promote energy efficiency and use of renewable energy sources. "In this way President Obama can contribute to fulfilling our 'moral obligation to future generations to leave them a planet that is not polluted and damaged'." Sincerely yours, Doug Grandt