Comments on the scope of the WesPac EIR, part 2

August 7th, 2015 – my second email submitting comments, focusing on climate change. Part one focuses on more local and regional issues.

This is the second part of my comments on the scope of the WesPac RDEIR, focusing on climate change, both the project’s effect on climate change and the effects of climate action on the project’s purpose and long-term viability.


It is not merely the manner in which the proposed WesPac project would operate that is a problem; it is its very existence itself. The purpose of the project is to increase the flexibility and capacity of the petroleum industry. It is likely to, however marginally, increase production of and reduce the costs of fossil fuels, and thereby increase the global use of those fossil fuels. And that is precisely the problem.

In a public comment of September 13, 2013, I said the following:

Even if the facility operated flawlessly, however, it would contribute to the increased global use of fossil fuels, which generates greenhouse gases that through climate change endanger our physical infrastructure, our health, our environment, and potentially the very viability of human civilization.

It is imperative that we change our energy system. To start with, we must insist on NO MORE FOSSIL FUEL INFRASTRUCTURE.

There is simply no excuse to do otherwise; any statement of environmental impact that claims low impact for additional fossil fuel infrastructure and allows its construction is extremely irresponsible.

Two years later that comment is, unfortunately, still valid. My claim that the very viability of our civilization is endangered is far from being an exaggeration. The climate change that is already “locked in” will strain our ability to adapt. The very material bases of our civilization are under assault: changing weather patterns mean that agriculture will be increasingly difficult, sea-level rise threatens many cities and much infrastructure, and more heat waves, storms, and cold spells mean more property damage and fatalities in the years ahead.

Much recent research has shown that climate change is happening faster than expected, and that the sensitivity of the climate to increased levels of heat-trapping gases (aka greenhouse gases aka GHGs) is on the high end of estimates. For instances, climatologist James Hansen and colleagues recently presented a paper (see ) in which they claim that existing climate models severely underestimate sea-level rise, and they predict that we might have as much as 10 feet of sea-level rise just in the next 50 years. That would put downtown Pittsburg (and the proposed WesPac site) underwater.

Morality, and the extra weight of symbolic significance

Climate change is fundamentally a moral issue, and therefore hard to address in the technocratic format of an EIR. Nevertheless, in this document I present some ways that we might attempt to think about the WesPac project in relation to climate change.

There are a couple standard ways that promoters of projects such as these try to get off the hook for the entirely foreseeable moral consequences of their actions, which I rebut here to prevent their glib inclusion in the EIR. One claim is a call to the fundamental amorality of the market: “if we don’t do it, someone else will, so we might as well do it and benefit from it”. Morally, that holds little water, but as a technocratic economic argument, it might. The second claim, somewhat related, is that the moral emphasis in a market society lies elsewhere than with producers: either with consumers, who can ostensibly refrain from buying a product whose production might entail moral harm, or with governments, who can pass regulations to mitigate or prevent that harm. While plausible at first glance, on deeper inspection we see that the same producing class has engaged in heavy promotion of their product to consumers, and heavy lobbying and ideological attack to prevent and minimize regulation. Nevertheless, for the second claim, if part of the moral responsibility lies with governments (as I believe it does), then that is all the more reason that the City of Pittsburg should deny a permit to a project of this kind.

As for the remainder of the first claim: in a perfectly fluid market, denying the WesPac project might just lead to a similar project somewhere else, with exactly the same effect on oil market dynamics. However, there are few examples of a perfectly fluid market. The site for the proposed WesPac project is a great match for the purpose they intend it for; other sites would function less well, and would therefore be less beneficial to the oil industry.

More importantly, the very nature of this as a contestation over morality, and a large-scale political struggle over the future of our society, means that our choice here has real weight. How much weight is hard to say, but sometimes these things have an influence far greater than we might suspect.

By analogy, look at the Keystone XL pipeline. In some ways, it’s just one more pipeline. Many have been built before it, and many are still being built. But climate activists decided to make it “a line in the sand”, and the huge controversy over Keystone has made visible and understandable the fight against climate change, the fight for our future against the profits of an ecocidal industry. In so doing, it has set a precedent that no pipeline will be easily built.

I sometimes view the WesPac project as the Bay Area’s Keystone XL. There are other projects in the Bay Area that will increase the fossil fuel industry’s capacity and flexibility. But this, as a brand new project in a place without a refinery, is notable. We have drawn the line in the sand. It has, whether its proponents like it or not, symbolic value which greatly magnifies its consequences. We have made it important; whether it is built or not will therefore have a greater effect on the future of the fossil fuel industry – and hence much greater environmental impact – than it would have when viewed as simply a piece of physical infrastructure.

It is not easy to quantify this symbolic significance, this extra weight, and therefore it’s hard to write about it in an EIR. But that does not mean that this is not a very real effect.

Request: I ask that this symbolic significance be included in the EIR, and that some attempts be made to determine its qualitative and quantitative effects. How will rejection or acceptance of this project affect the moral viability of other fossil fuel infrastructure projects? Put another way, what are the consequences of moral leadership on this issue?

Specific consequences of enabling crude slate change

Leaving aside the harder-to-measure consequences of this symbolic significance, the WesPac project would likely lead to increased GHG emissions, above and beyond any emissions directly associated with its construction and operation.

The WesPac project is likely to bring in new types of crude, particularly tar sands dilbit. Tar sands is an incredibly dirty fuel source, and its production is energy-intensive. It takes an enormous amount of energy (usually produced by burning natural gas) to get the tar sands out of the ground. Pre-processing the tar sands into a form suitable for transport takes a lot of energy and produces a lot of CO2. Its transport and storage often requires heating equipment and high pressure. Its refinement into finished products such as gasoline also requires more energy than other crudes.

Gasoline and diesel produced from this process has a lot of GHG emissions behind it, separate from those produced when the fuel is burned.

Request: I ask that the EIR include estimates of the additional GHGs that would be emitted, throughout the whole mining-to-refining process, by changing the crude slate of regional refineries to include a high percentage of tar sands.

Consequences of climate action on purpose and viability

For all this doom and gloom, there is good news. Slowly, the tide is turning. The climate movement is winning, through many different strategies. The new Clean Power Plan is but one example, as are the new California goals for fuel efficiency and renewable electricity. We can expect more change in the regulatory environment in future – whether that’s a reduction in fossil fuel subsidies, a price on carbon of some kind, government acceleration of the rollout of renewable electricity and electric vehicles, or even a massive overhaul of our transportation infrastructure. All of these are likely to reduce the demand for gasoline and diesel and therefore impact the viability of the WesPac project.

Furthermore, there are a couple of other factors that imply less demand for gasoline and diesel in the next decade or two. There appears to be a generational shift: people now under 40 are markedly less interested in owning a car and in driving than previous generations. Also, electric vehicles (EVs) are gaining in popularity. It is important when thinking about technology like EVs to realize that the adoption curve is usually exponential, not linear. We see this in solar today. This article discusses the idea that, counter-intuitively, 1% is “halfway to market dominance”: EVs have 2+% market share of new cars in California, about 0.7% in the US as a whole.

Request: I’d like to see some projections – different scenarios – for how climate action and technology affect demand for gasoline and diesel over the next 20 to 30 years. One set of scenarios should specifically look at different carbon price scenarios and the consequences. You may find this carbon price forecast helpful:

Request: I’d like to see projections of the consequences of this reduced demand on Bay Area refineries. How many will close in the next 20 to 30 years? How does that affect the purpose and economic viability of the WesPac site?


Lastly, the movement to divest from fossil fuel stocks is the fastest growing divestment movement ever. Its goal is not just to hurt the industry financially, but to hurt its political power and its “social license to operate”. Again, these are hard effects to quantify, but at some point are likely to impact the industry in a noticeable way.

Request: I ask that the EIR consider how fossil fuel divestment might affect the ability to finance the WesPac project, and how it might accelerate the financial and political decline of the fossil fuel industry from the factors above.

Thank you,

Martin MacKerel


I sent one more quick email before the 5pm deadline, having found this article:

Thanks. One quick, but striking update, that supports my point about electric vehicles and reduction of demand for gasoline, and should be included as a scenario. California may aim to have all new cars emission-free by 2030:

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