Letter to State Dept 14-02-09 KXL

8/13/2019 Letter to State Dept 14-02-09 KXL

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506

February 9, 2014

Bureau of Energy Resources, Room 4843Attn: Keystone XL Public Comments

U.S. Department of State2201 C Street NWWashington, DC 20520

Re: TransCanada permit application for the Keystone XL pipeline

Dear John Kerry and Barack Obama:

Beginning 1972, my second job following two years doing computer simulations of PrudhoeBay Reservoir for ExxonMobil, then Humble Oil & Refining Co., was as the first CorporatePlanner at a Fortune 500 ocean transportation company transitioning from breakbulk tocontainerization. Having studied Industrial Engineering/Operations Research and PetroleumEngineering at the University of California (Berkeley) I yearned for a birds-eye-view of the

Corporate world and found my ideal niche as understudy for a tough but moral NavalArchitect mentor who taught me to speak the language of the Board of Directors in my late30s. Frankly, I am an engineer/scientist at heartI enjoyed analysis and the search for truthmore than the glossy packaged presentations.

In many ways, the Final Supplemental Environmental Impact Statement (FSEIS) violateswhat I have strived to accomplish throughout my entire 42-year career, invalidating all thework that has gone into its preparation.

Section 1.4 Market Analysis verbiage in the FSEIS wreaks of a K Street MBA for hireCorporate Strategy Consultants highfalutin and obfuscating lingo.

From Section 1.4 Market Analysis 1.4.1.3 Summary of Analysis (page 1.4-8):

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One thing I would never do as a young Corporate Planner is leave unresolved phrases likehigher transportation costs could have a substantial impact on oil sands production levelswithout some explanation as to why such a comment plays no role in the conclusion. Sinful isthe poignant phrase that immediately follows: ... possibly in excess of the capacity of theproposed Project.

I wonder what the authors, editors and managers had in mind with this:

As a result, the price threshold above which pipeline constraints are likely to have alimited impact on future production levels could change if supply costs or productionexpectations prove different than estimated in this analysis.

Do they expect us to believe the conclusions with this hanging out there?

The coup de grce of this section: Oil sands production and investment could slow oraccelerate depending on oil price trends, regulations, and technological developments,but the potential effects of those factors on the industrys rate of expansion should notbe conflated with the more limited effects of individual pipelines. Nowhere is this claimsubstantiated.

This wreaks of pure sales promotionnot objective and transparent analysis constructed toprove a priori that the pipeline and production are not linked.

Section 1.4 Market Analysis 1.4.5.4 Implications for Production, beginning at page 1.4-131presents the same unsubstantiated speculations and circular arguments:

Douglas GrandtFebruary 9, 2014

Encl.: My letter dated March 19, 2013

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Continuing on page 1.4-132:

What are the assumptions built into the model that generate this conclusion?

Model results indicate that if additional pipelines to Canadas West Coast areconstructed, they would most likely be utilized regardless of the availability of cross-border pipelines due to the economic attractiveness of the relatively short seaborneshipping distances from Canadian export terminals to refineries in Asia.

One fundamental requirement I learned in 1972 was to state my assumptions. We have noway to judge whether the assumptions used here are valid.

Continuing on page 1.4-133:



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What is the basis for this conclusion and how does it play in the argument?

Consequently, imposing a constraint exclusively on future cross-border pipelinecapacity does not cause a significant reduction in the modeled prices of oil sandsblends or the returns to oil sands producers.

The assumptions implied by the statements in the very long paragraph above are speculative,tenuous, and pipe dreams at best. Hinging conclusions on a house of cards is not my ideaof professional and objective work.

Transparency dictates that the authors lay out the logic of their arguments concisely, clearlyand comprehensively in advance of presenting the elements.

Simply running models and generating results without a clear explanation is an insult to theaudience. In my March 19, 2013, letter during the last 45-day comment period, I stated thefollowing (http://bit.ly/StateDept19Mar13KXL):

There is no transparency as to guiding principles and assumptions of the Keystone XLSIES.Unless and until the structure of the SEIS is revealed, and the guidelines and

assumptions are clearly laid out for all to see and understand, the SEIS cannot beobjectively assessed.Statements that it is consistent with the National EnvironmentalPolicy Act are not sufficient.

A concise explanation of what is intended to be demonstrated in a problem as complex asthis should be demanded by the owner, in this case, the State Dept.

I find nothing that clearly demonstrates that Keystone XL would not play an important role theexpansion of Canadian bitumen extraction. Lacking such, the intelligent reader shouldconclude that Keystone would contribute to the deleterious effects of climate change broughtabout by the combustion of the fossil fuels produced from tarsands that it would transport tomarket.

The Keystone XL pipelinelike other means of bitumen transportdoes nothing toinhibit, slow down or stop the extraction of Canadian bitumen.

Keystone XL only has the potential to exacerbate a climate catastrophe.

Keystone XL is not in the National Interest. Its only purpose is to move fossil fuels to market. Itsconstruction and operation is contraindicated, as is any other means of transport of thetarsand bitumen from Canada to be burned.

Facilitating the transport and combustion of increasing amounts of fossil fuels includingbitumen is not in the National Interest because of the disastrous effects of the resultingchanges in climate in the USA as well as globally.

The Keystone XL pipelines potential to facilitate bitumen excavation and combustion is not inthe National Interest.

Curtail Keystone XL.Commence Retiring Refineries.Compel the oil industry to Replace Refineries with Renewables.

Taking these three actions as quickly as possible is in our National Interest.

Sincerely yours,

Doug Grandt



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Douglas A. GrandtP. O. Box 1582

El Dorado, CA 95623

March 19, 2013

U.S. Department of StateAttn: Genevieve Walker, NEPA Coordinator

2201 C Street NW, Room 2726Washington, D.C. 20520Re: Keystone XL Pipeline SEIS guidelines and assumptions

Dear Ms. Walker,

There is no transparency as to guiding principles and assumptions of the Keystone XL SIES.Unless and until the structure of the SEIS is revealed, and the guidelines and assumptionsare clearly laid out for all to see and understand, the SEIS cannot be objectively assessed.Statements that it is consistent with the National Environmental Policy Act are not sufficient.

President Obama and Secretary Kerry should send the SEIS back to the drawing boardrequiring that the basic guidelines and assumptions be clearly stated, and that it be updatedwith the global impacts of excavation, forest destruction, processing, river contamination (alltoxins and carcinogens), transporting, refining, and ultimate burning of the tarsands bitumen.

In the late1960s, I degreed in Industrial Engineering, Operations Research and PetroleumEngineering. My first job was with the largest oil production and refining corporation in theworld. Doing Corporate Planning (1972-1979), I learned the absolute necessity to documentall of the assumptions that were the basis of my work. Now retired, I believe it is fundamentalto the credibility of the SEIS that you clearly state the assumptions and expose the biases.

Sincerely yours,

This fence is a "wall" of ignorance, arrogance, politics and deceit.

Letter to State Dept 14-02-09 KXL

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