8/13/2019 Letter to State Dept 14-02-20 KXL

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506

February 20, 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:

I have previously criticized the FSEIS for using incremental and displaced without apparentexplanation. After two weeks of pouring over the FSEIS, I have not found a central, readilyidentifiable list of assumptions, easy to understand and unmistakable as to its importance.

Critical is the assumption that the greenhouse gases associated with the construction of the

Keystone XL project and the combustion of the fossil fuels associated with liquids and solidsand gases that would be transported are assumed to displace or substitute for other fuelselsewhere in the world. It is as though Keystone XL and some amorphous other project aremutually exclusive one project precludes the other warranting an increment analysis.

This key finding is found in 4.14.1.3 Summary of Key Findings (pages 4.14-4 and 4.14-5):

The total annual lifecycle emissions associated with production, refining, andcombustion of 830,000 barrels per day (bpd) of oil sands crude oil transportedthrough the proposed Project, as determined through this assessment, areapproximately 147 to 168 MMTCO2e. The equivalent annual lifecycle GHGemissions from 830,000 bpd of the four reference crudes (representing crude oilscurrently refined in Gulf Coast area refineries) examined in this section areestimated to be 124 to 159 MMTCO2e. The range of incremental GHGemissions (i.e., the amount by which the emissions would be greater than thereference crudes) for crude oil that would be transported by the proposed Project isestimated to be 1.3 to 27.4 MMTCO2e annually. This is equivalent to annual GHGemissions from combusting fuels in approximately 270,833 to 5,708,333passenger vehicles, the CO2 emissions from combusting fuels used to providethe energy consumed by approximately 64,935 to 1,368,631 homes for 1 year, orthe annual CO2 emissions of 0.4 to 7.8 coal fired power plants.

These emissions are incremental which is explained parenthetically as the amount bywhich the emissions would be greater than the reference crudes.

Table 4.14-4 on page 4.14-35 provides another explanation that the emissions areincremental over displaced reference crudes. Without explaining why, calculations of thecarbon content of reference crudes is a significant documentation effort within the FSEIS.Here we have a significant foot note c but no explanation of the underlying assumption:

c The substitution credit represents petroleum coke production that goes into fuels markets,

which results in more coke consumed and displaces the consumption of some coal.

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If the reader wonders what exactly is this Substitution Credit, footnote c explains only that itis the incremental difference between petroleum coke and coal that it displaces.

The right-most column heading is Net GHG Emissions from Production, Combustion ofPetroleum Coke and Other Co-Products and Coal Substitution. Hence, we can concludethat displaces in the footnote and substitution in the column heading are synonymous.This makes sense. What does not make sense, or is not intuitive is that the right-mostcolumn is not equal to the simple subtraction of the middle column from the left-most column.

The Note at the bottom of the table explains what must be taken as fact:

Because these values represent a range drawn from the results of various studies, it is not

possible to add them together to get to the net emission results. Instead, the results from one

study need to be consistently summed with results from that study to produce the final result.

Accepting the explanation, we are only left to observe that the Net GHG is a very smallpercentage of the total emissions in the left-most column, on the order of zero to 10 percent.

Douglas GrandtFebruary 20, 2014

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Now, does this mean that the LCA (Life Cycle Analysis) or WTW (Well to Wheel) foot print ofemissions in the FSEIS is zero or the 10 percent equivalent when it should be the full amountbefore the substitution credit? This is either undocumented or very obscurely placed where Ioverlooked it I simply have not found it yet but as I have written in an earlier letter, thewording makes me believe that it is assumed insignificant and simply swept under the rug.

Finally, my question to D.O.S. and the authors of the FSEIS is why is this an incrementalanalysis? All of the emissions from the processing, upgrading, transportation, refining andcombustion of the fuels and co-products from the entire feedstock should be accounted forand charged to the Keystone XL under the various scenarios using the range of sensitivityscenarios in my previous letters.

The Keystone XL will deliver heavy crude into the world market via the products from GulfCoast refineries, and what happens to the heavy crude from South America or the MiddleEast is irrelevant. With the increasing demand for fuels, it should not be presumed that itwould be a zero-sum situation. Especially, the stockpiling of petcoke should not be given anexemption from accounting it should be assumed that the petcoke will eventually be soldand burned. The Keystone XL should get the full load of all emissions from all products and

co-products.

The impact of a full accounting would be to elevate the number of vehicles, homes and powerplants in the bulleted key finding at the beginning of this letter:

Equivalent items FSEIS GHG TOTAL GHG

Annual lifecycle GHG 1.3 to 27.4 MMTCO2e 147 to 168 MMTCO2e

Passenger vehicles 270,833 to 5,708,333 30.6 to 35.0 million

Homes 64,935 to 1,368,631 7.3 to 8.4 million

Coal-fired power plants 0.4 to 7.8 45.2 to 47.8

Using total emissions instead of the mere increment reveals the astonishing understatementthat the FSEIS portrays as the equivalent passenger vehicles, homes and power plants thatare associated with the fossil fuels that Keystone XL delivers to the world markets

At the maximum of the range, the emissions would be 168 MMTCO2e, not 27.4 MMCO2e.

Similarly, the equivalent passenger vehicles would be 35 million not 5.7 million

Similarly, the equivalent number of homes would be 8.4 million, not 1.4 million.

Similarly, the equivalent coal power plants would be 47.8, not 7.8

These are huge understatements ... the FSEIS authors and D.O.S. managers must explainthe rationale for the construction of the analysis on an incremental basis, transparently.

Sincerely yours,

Doug Grandt

Douglas GrandtFebruary 20, 2014

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