Douglas A.

Grandt
PO Box 6603
Lincoln, NE 68506
February 15, 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:
Conclusions from testing various combinations of market and pipeline scenarios using the
EnSys World Oil Refining Logistics & Demand (WORLD) model leads the authors of the
FSEIS and the DOS project managers to conclude:
Updated model results indicated that cross-border pipeline constraints have a
limited impact on crude flows and prices. If additional east-west pipelines were built
to the Canadian coasts, such pipelines would be heavily utilized to export oil sands
crude due to relatively low shipping costs to reach growing Asian markets. If new
east-west and cross-border pipelines were both completely constrained, oil sands
crude could reach U.S. and Canadian refineries by rail.
From Section 1.4 Market Analysis 1.4.1.3 Summary of Analysis (page 1.4-3):
This suggest that U.S. consumers have no free will or that the public cannot influence policy.
If circumstances evolve to a ban on cross border pipeline or popular resistance against any
east-west Canadian pipelines (thus sealing off the lowest-cost means to transport tarsands),
the implication is that the citizens of Canada and the United States of America have put their
foot down and said no!
To utilize rail tanker trains to do an end run would violate our trust in ethical principles. Slow
leaks, disastrous spills, derailments, explosions, asthma, cancer, incineration. Rail or pipeline?
is a false choice. Neither is desiredcontraindicated by people of science and of conscience.

The problem with the Final Supplemental Environmental Impact Statement (FSEIS) is that
sixteen combinations of markets and transportation scenarios seem to cover the gamut (see
enclosed 1.4.4.2 Scenarios). Not evaluating critical missing scenarios is unconscionable.
Missing critical scenarios are not apparent for a lack of transparent underlying assumptions.
A missing scenario is US consumers consuming less fossil fuel to save the planet. Another is
US consumers refusing to allow rail tanker trains or pipeline transport risks at the expense of
our communities, our water resources, our breadbaskets, our property, and our home, Earth.
Take a closer look at penultimate sentence. It reveals a clue to an unanswered question that
nobody dares to ask, and which the FSEIS authors have hidden in a clever choice of words
and phrases:
Read this carefully, and notice the two distinct objects of the phrase prices U.S. consumers
pay, i.e., 1) for refined products such as gasoline and 2) for heavy crude demand in
the Gulf Coast presented in high-contrast highlights here for your convenience:
Varying pipeline availability has little impact on the prices U.S. consumers pay
for refined products such as gasoline or for heavy crude demand in the Gulf Coast.
People purchase gasoline for their vehicles. Refineries purchase heavy crude to process.
This is very subtle, but the nuance is glaring once you see it. Is it obfuscation? Subterfuge?
Ironically, the final sentence is apropos of lethal drug choice metaphors sometimes alluded,
lumping Canada together with Latin America and the Middle East as suppliers to our demand:
When this demand is not met by heavy Canadian supplies, it is met by heavy crude
from Latin America and the Middle East.
Who is the consumer of the tar sand bitumen in this global market that is being analyzed by
WORLD? Who are the U.S. consumers who demand heavy crude? Canadian refineries on
the Canadian coasts? No. U.S. refineries in the Gulf Coast whose primary product is diesel
for export markets. A subtle clue in Section 1.4 is heavy crude has limited diesel export value.
Refineries demand a stable flow of feedstock that matches their optimized configuration and
at the least cost in order to maximize already thin profit margins.
Keystone XL aids and abets the refineries demand for heavy crude, feeding needed supplies.
Eliminating refinery demand for heavy crude will solve the climate crisis, ending investments
being sunk into tarsands excavation, SAGD, and pipeline projectswith renewable energy
projects and infrastructure replacing refineries. No Keystone XL is in the National Interest.
Say no! to rail, tanker trains, and pipelines. Say no! to derailments, spills, and explosions!
Sincerely yours,
Doug Grandt
Encl.: 1.4 Market Analysis, 1.4.4.2 Scenarios (pages 1.4-92, 1.4-93 and 1.4-94)
Douglas Grandt
February 15, 2014

Final Supplemental Environmental Impact Statement Chapter 1
Keystone XL Project Introduction
1.4-92
'The AEO ReIerence case reIlects some important updates, including more rapid near-
term growth in U.S. tight oil production, a lower near-term trajectory Ior oil prices, and
reduced U.S. gasoline demand due to higher vehicle eIIiciency. However, these updates
do not alter some oI the major implications oI earlier projections, including continued
U.S. dependence on imported crude oil supplies, growing global demand, long-term
rising oil prices, growth in Canadian oil sands production, and continued demand Ior
heavy crude by U.S. GulI Coast reIiners even as traditional sources Irom Mexico and
Venezuela continue their recent declines. (EIA January 2013 Memo, see Appendix C,
Supplemental InIormation to Market Analysis)
However, in response to comments Irom the public and other agencies, the Department
commissioned an update oI the EnSys modeling to explicitly incorporate recent developments.
Scenarios reIlecting key uncertainties raised in comments Irom the public and other government
agencies were incorporated into this eIIort. As a result 16 diIIerent scenarios were modeled with
updated data and supported by additional analysis such as the transportation inIormation in
Section 1.4.3, Crude Oil Transportation. Questions examined in various scenarios include the
impact oI shiIting oil production and consumption trends, the markets Ior WCSB crudes, the
impact on U.S. oil imports, and the implications Ior crude transport by rail.
!"#"#"$ %&'()*+,-
In response to comments and to assess key uncertainties regarding supply, demand, and pipeline
availability, the EnSys WORLD model was applied to Iour supply-demand cases and Iour sets oI
pipeline conIigurations. Each supply-demand case was modeled against each pipeline
conIiguration to yield the 16 scenarios as shown in Table 1.4-19. The WORLD model generated
projections through 2035 in each scenario. The supply-demand cases modeled are as Iollows:
The ReIerence Case projection, in which U.S. crude production reaches 7.5 million bpd by
2016 to 2020 and thereaIter gradually declines to 6.3 million bpd by 2035.
The EIA AEO High Oil and Gas Resource Case projections, where U.S. crude oil production
reaches 10 million bpd by 2020 and remains around that level thereaIter (natural gas
production is also elevated in this case, keeping natural gas prices lower than in the
ReIerence Case).
The EIA AEO Low/No Net Imports Case projections, a supplement to the High Resource
Scenario that also assumes U.S. oil consumption Ialls a Iurther 2.8 million bpd by 2035
relative to the High Resource Case and the United States becomes a net oil exporter.
A supply-demand case which assumes higher than expected oil production in Latin America.
The High Latin America case assumes the region produces 2.5 million bpd more oil than the
ReIerence Case by 2020 and 3.5 million bpd by 2035. This would result in total Latin
American liquids supply oI 14.3 million bpd in 2020 and 18.4 million bpd in 2035. This
scenario does not represent a Iorecast, but rather a hypothetical scenario to understand the
implications oI uncertainty.
Final Supplemental Environmental Impact Statement Chapter 1
Keystone XL Project Introduction
1.4-93
Table 1.4-19 Supply-Demand and Pipeline Cases, and the Resulting Scenarios

EIA AEO
Reference Case:
U.S. crude oil
production peaks at
7.5 million bpd in
2019 and then
declines
EIA AEO High
Resource Case:
Larger recoverable
oil and gas resource
assumptions result
in U.S. crude oil
output reaching
10 million bpd by
2020 and then
remaining Ilat
EIA Low/No
Imports Case:
Assumes High
Resource supply
plus greater
demand-side
eIIiciency, leaving
United States a net
oil exporter by 2035
High Latin
American Supply
Case: Assumes
higher Latin
American
production with
ReIerence Case
Unconstrained:
Allow all cross-
border and
Canadian east/west
pipelines
Reference
Unconstrained
Scenario
High Resource
Unconstrained
Scenario
Low/No Imports
Case Unconstrained
Scenario
Higher Latin
American
Unconstrained
Scenario
No East-West
Pipelines:
Allow cross-border
pipelines but no
new Canadian
east/west pipelines
or rail to Canadian
West Coast
Reference No East-
West Scenario
High Resource No
East-West Scenario
Low/No Imports No
East-West Scenario
Higher Latin
American No East-
West Scenario
No Cross-Border
Pipelines:
No cross-border
pipelines but allow
Canadian east/west
pipelines
a

Reference No Cross-
Border Scenario
High Resource No
Cross-Border
Scenario
Low/No Imports No
Cross-Border
Scenario
High Latin
American No Cross-
Border Scenario
All Constrained:
No new cross-
border, east-west
Canadian pipelines,
or rail to Canadian
West Coast
Reference
Constrained
Scenario
High Resource
Constrained
Scenario
Low/No Imports
Constrained
Scenario
High Latin
American
Constrained
Scenario
a
Where permitted, planned pipelines begin aIter several years, including the northern leg oI TransCanada Keystone XL (2017),
TransCanada Energy East (2018), expansion oI Kinder Morgan Trans Mountain (2020), and Enbridge Northern Gateway (2025).
Key aspects oI the AEO cases were described above.
126
126
Additional details are available in the AEO (EIA 2013a).
The additional Latin America scenario
was included to examine uncertainty that this region, traditionally the source Ior heavy crude oil
imports into PADD 3, would produce more heavy oil than expected in the ReIerence Case.

Each oI these supply-demand cases was paired with Iour pipeline conIigurations:
An Unconstrained pipeline scenario, where pipelines are assumed to be built as warranted by
market conditions.
A No East-West Pipelines scenario, where new pipelines capacities between the United
States and Canada are permitted as dictated by market need but no new pipelines Irom
Canada`s oil sands region to Canada`s East or West Coast are permitted by Canadian
Final Supplemental Environmental Impact Statement Chapter 1
Keystone XL Project Introduction
1.4-94
authorities. Crude by rail to the Canadian West Coast Ior onward overseas shipment by
tanker to Asia is also not permitted.
A No Cross-Border Pipelines scenario, where pipelines within Canada are assumed to be
built as dictated by market conditions but no new cross-border pipeline capacity into the
United States is permitted.
A Constrained Pipelines scenario, which assumes that no new pipelines carrying WCSB
crude are built. Like the No East-West Pipelines scenario, no additional crude by rail to the
Canadian West Coast is permitted.
In scenarios where pipelines were constrained, increased crude shipment by rail was allowed
subject to the constraints described above.
127
127
In all scenarios, rail transport oI crude oil was permitted with two exceptions. As outlined in Table 1.4-14, rail to
the Canadian West Coast is constrained in scenarios where new pipelines Irom the WCSB to the Canadian West
Coast are not permitted. Due to relatively low costs to reach markets in Asia whether by rail or pipeline results
allowing westbound rail transport where westbound pipelines were not allowed appeared substantially similar to
permitting westbound pipelines. This overwhelms the impacts oI changing other variables. Rail transport to Eastern
Canada Ior export was not as similar to pipeline transport and does occur in some scenarios, but not others. Also,
potential rail shipments to the U.S. West Coast Ior export were constrained to 0.1 million bpd or less.
The WORLD model projections Ior oil sands crude
by rail are Ior rail shipments oI dilbit, which contains approximately 30 percent diluent. This is
the least economic means oI transporting oil sands crude by rail, as discussed in Section 1.4.3.3,
Potential to Increase WCSB Crude by Rail.

In reality, growing volumes oI bitumen by rail may be shipped as railbit or rawbit, which
requires less or no diluent. The model does provide prices Ior railbit and dilbit in the GulI oI
Mexico based on reIiner demand Ior comparable crudes. The economics oI railbit and rawbit are
considered in Section 1.4.5.3, Transportation Cost Sensitivities. Rail transport costs in WORLD
rise over time as diesel costs rise with global oil prices.
Two previous scenariosdenying the proposed Project but allowing other new cross-border
pipeline capacity and not allowing any new transport capacity out oI the WCSBdid not need to
be updated because results Irom the EnSys 2010/2011 modeling would be unaIIected by recent
changes:
In a scenario where the proposed Project is not built but other new cross-border capacity is
permitted, then other, broadly similar pipeline capacity is likely to be built between the
WCSB and PADD 2 and PADD 3. This has been borne out in recent pipeline proposals, in
particular the Alberta Clipper Expansion and Flanagan South proposals.
In a scenario where it is assumed that all transportation options are Irozen at current levels,
little additional production Irom the WCSB would be possible (production would be capped
at current export capacity). This scenario remains unrealistic, and is contrary to the ongoing
trends in increasing rail capacity that have been developing since the middle oI 2011. Any
assumption that rail capacity remains at current levels would be inconsistent with the
developments described above, including projects currently under construction.