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On Keystone XL Final Supplemental Environmental Impact Statement: GHG Analysis & Next Steps

Thanks for your comments, Bob. I agree that US agencies do not yet have any handle on how to assess whether US actions will help or hinder other countries' climate regulations. To be fair, that is an extremely difficult and complex question, which is why some have suggested that it may not even be possible to calculate the benefit of domestic climate action (or the social cost of carbon) given that the real intent of domestic actions is to spur international efforts. I have a forthcoming article in the Harvard Environmental Law Review that discusses ways that domestic action can be calibrated to encourage action in other countries. 

You also note the interesting disconnect between the industry's focus on pipeline capacity and State's conclusion that even if all pipelines are constrained, oil sands production will be unaffected. For what it's worth, I think State would acknoweldge that pipeline constraints are a *risk* for the oil sands: after all, if oil prices fall *and* pipelines are constrained, State says there would be a substantial affect on the oil sands.  But State would say that, despite that risk, the *most likely* scenario is that oil sands production is not affected, producers just pay a bit more for transport and earn a bit less profit. That being said, I agree that it's hard to imagine that increased profitability won't have some impact on future investment, at least on the margin, but that's how State would square the circle, I believe.

February 23, 2014    View Comment