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The Only Public Comment Kerry Needs to Deny Keystone XL

By Michael Collins - Posted on 17 April 2013

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Any project that increases greenhouse gasses above expectations at this moment in history, particularly a substantial increase, must be determined an imminent danger to the national interest if the people living in the nation are an interest in this determination.

The United States Department of State called for public comments on construction of the Keystone XL pipeline.  The deadline is April 22, 2013 -- Earth Day.  Since Keystone is an international project, Secretary of State John Kerry has authority to decide on starting or ending the proposed conduit for toxic oil from the Alberta, Canada tar sands, across the United States, to the Houston area for refining.  From there, the oil goes straight to China.

Tar sands oil produces 17% more carbon dioxide per barrel than the average barrel of oil.  With China's intense demand for fuel, the volume of carbon dioxide pumped into the atmosphere will increase at a dangerous rate even beyond the current hazardous rate of pollution. 

Public Comment follows the break

I'm not the only person making the arguments that follow.  A long list of eminent scientists stand opposed to the project.  My comment is likely shorter than theirs and it's from an ordinary, concerned citizen.  Take a look and, if you agree, modify it or send it as is to Send your U.S. senators and congressperson a copy as well.

Coping with the outcome of climate change is an extremely serious challenge right now.

Why make it even worse?


Comment on the National Interest Determination - Keystone XL Pipeline

The March 13, 2013 Keystone Draft Environmental Impact Statement (EIS) specifies the influence of Alberta, Canada's tar sands heavy crude oil on climate change.  Tar sands oil produces 17% more greenhouse gasses than the average barrel of oil. (1)  While the EIS assessed "Climate Change Effects on the Project," the impact of increased greenhouse gasses on citizens of United States was not addressed.  This impact is the essence of any national interest determination that examines Keystone XL and similar projects.

The EIS concludes that since nearly the same volume of Alberta tar sands crude oil will be transported to refineries without the Keystone XL pipeline, denying project approval would have only a marginal impact on tar sands oil production and, by implication, greenhouse gas emissions. (2)

Based on the explicit admission of 17% greater greenhouse gasses per barrel from Keystone XL, the Secretary of State must deny approval of the pipeline even if every single assertion in the Environmental Impact Statement stands up to challenges by opponents.


Any project that increases greenhouse gasses above expectations at this moment in history, particularly a substantial increase, must be determined an imminent danger to the national interest if the people living in the nation are an interest in this determination.

The EIS conclusion that since other methods of transport are available therefore Keystone XL has only a marginal impact on greenhouse gas emissions is tragically flawed logic.  How would we react if the Drug Enforcement Administration passed up an opportunity to shut down one of the nation's largest meth labs because other sources of crystal meth would soon rise up to meet demand?

What impact will the 17% increase in greenhouse gasses have on the stability of the earth's climate?  A 2 degree C increase in global temperature is the consensus limit before life in parts of the United States becomes intolerable due climate events. (3)(4)  Extreme climate events today will be tomorrow's normal if that limit is exceeded. (5)(6)   The atmosphere can tolerate an additional 430 billion metric tons of carbon before breaching the 2 degree barrier.  Based on estimates that did not include Alberta tar sands oil, that limit will be reached in the summer of 2041. (7)

Complete extraction of Alberta tar sands oil will produce 198 billion metric tons of carbon above and beyond the original estimates -- 46% of the total carbon left before the 2 degree tipping point is reached.  Just with today's technology, 22 billion metric tons of carbon will be added to the total produced -- around 5% of the remaining total.

The rate of climate change is accelerating. (8)   The 2 degree C target seems unrealistic providing an even stronger rationale to stop the toxic flow of Keystone XL.


Submitted by Michael Collins

(1) Department of State, Draft Supplemental EIS --Keystone XL Project, Executive Summary, March 2013, p. ES-15.
(2) Ibid. p. ES-15.
(3) Saeger, Richard, Persistent drought in North America: a climate modeling and paleoclimate perspective. Lamont-Doherty Earth Observatory of Columbia University, July 2010.
(4) California Climate Change Center, Reports on the Third Assessment from the California Climate Change Center, July 31, 2012.
(5) Intergovernmental Panel on Climate Change (IPCC), Fourth Assessment Report: Climate Change 2007.
(6) Barnosky, Anthony D et al., "Approaching a state shift in Earth’s biosphere," Nature (June 7, 2012):  52–58.
(7) Myles, Allen R. et al., "Warming caused by cumulative carbon emissions towards the trillionth tonne," Nature 458 (April 30, 2009):  1163-1166.
(8) Peters, Glen P., et al., "The challenge to keep global warming below 2 °C," Nature Climate Change 3 (2013), 4–6

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