Month: July 2022

Practicing to Get Good at Public Comment Letters

The White House got a lot of email from me today… sorry about that.

I wrote in my recent multiproject update that I wrote a public comment letter for the first time (about the SEC proposed climate disclosure rule):

I followed the guidelines from the Public Comment Project, and squeaked my email in just before their extended deadline of June 17th. I was worried I had bungled the submission because I didn’t see my comment on their public comments page, and I still might have, but according to this article it typically takes a month or two before the comments are posted. So I’ll be keeping my eye on that page to see if I did it right. I definitely want to keep doing these in the future, because it’s an effective way to influence climate policy. (If you want to read my comment, I’ve appended it at the end of [that] post!)

I wrote three more today. These were easier, because the advocacy newsletters I’m on sent me a form-letter to personalize. For each of them, I ended up mixing their talking points with some of my own that I’ve collected through my research quest. I’ve appended my three letters below.

I think advocating in writing is a great skill for an environmentalist to have! The first was kind of nerve-wracking, but hopefully by the 200th this will be a breeze.

If you want to start sending comment letters of your own, I’ve linked the three campaigns I wrote for below, and here are a couple of super-quick (US-centric) tips:

  • To find issues to write about, you can sign up for environmental email lists that will send them to you, complete with a form letter for you to modify. I favor League of Conservation Voters, Green New Deal Network, 350.org, and  Climate Hawks Vote. They may sometimes ask for donations, but I have found these particular organizations’ emails informative and infrequent.
  • If you’d rather not get emails, you can also go on mobilize.us and search for the keywords ‘climate’ and ‘letter’.
  • Check out the examples on the Public Comment Project (and generally that whole site) to get an idea of the tone to strike.
  • If you plan on modifying the templates (which I believe is optional, but I always do for self-expression reasons), you may want to make a master research document for yourself, so you can repurpose your personal set of talking points.

These are the three campaigns the letters were for:

  1. Letter for the Action Network letter campaign: Tell Biden and BLM to say no to the Willow Project!

    The Willow is a massive project that includes up to 250 new drilling wells, as well as hundreds of miles of roads, airstrips, and a new fossil fuel processing facility. All this in an area of the Arctic that is already warming at twice the rate of the rest of the country and is affected most by climate change.

    Not only would Willow break a promise Biden made not to expand fossil fuel drilling in the sensitive arctic, it would make it impossible for him to achieve his goals of limiting global temperature increase to 1.5 degrees Celsius.

    Send a comment now and tell BLM and Biden that they cannot permit the Willow plan, or any fossil fuel project with this kind of impact on the climate or the Arctic.

    https://actionnetwork.org/letters/tell-biden-and-blm-to-say-no-to-the-willow-project?source=email&

  2. A campaign from the the League of Conservation Voters to prevent more oil drilling leases. “For years, we have fought (and won!) against attempts to expand offshore drilling. But a new round of drilling leases in our federal waters is now under consideration. We cannot hand our public waters over to private oil companies.

    If Big Polluters get their way, oil companies would be able to drill in new waters and lock us into decades of fossil fuel destruction and dependency. This puts our coastal communities, marine life, public health, and the climate at an unimaginable risk.

    To protect our climate, oceans, and communities, we must prevent these drilling leases from moving forward! Submit a comment to the Department of the Interior to keep Big Oil out of public waters!”

    https://actnow.lcv.org/afimpis

  3. Another from the League of Conservation Voters, urging the Biden admin to use their executive powers.

    “The White House and the Biden administration have significant power to cut pollution and curb the climate crisis — and they must use it boldly and swiftly.”

    https://actnow.lcv.org/TzX1s0G

* * *

Here are my letters. (Note that they are not entirely original; some passages are from the form letters. Feel free to borrow points from it as well.)

Letter 1: Against Willow Master Development Project.

I am writing to express my strong opposition to the Willow Master Development Plan Supplemental Environmental Impact Statement.

Willow is a massive project that includes up to 250 new drilling wells, as well as hundreds of miles of roads, airstrips, and a new fossil fuel processing facility. All this in an area of the Arctic that is already warming at twice the rate of the rest of the country and is affected most by climate change.

President Biden has already taken the admirable step of committing to a 50-52% reduction in GHG emissions by 2030 and net-zero emissions by 2050 as a part of the US Nationally Determined Contribution, and issuing an Executive Order on January 27, 2021 to place the climate crisis at the forefront of this Nation’s foreign policy and national security planning.

Unfortunately, allowing the Willow Master Development Plan will certainly place the fulfillment of these promises out of reach.

The International Energy Agency issued a report (https://iea.blob.core.windows.net/assets/deebef5d-0c34-4539-9d0c-10b13d840027/NetZeroby2050-ARoadmapfortheGlobalEnergySector_CORR.pdf) stating that pathways to net-zero by 2050 should include NO new investment in oil and gas. In contrast, the Willow project will lock in oil and gas production infrastructure for decades to come.

Additionally, this project will do nothing for decreasing gas prices. Rising gas prices are a real and burdensome problem for Americans, caused primarily by global markets and shameless price-gouging by producers.

As the administration is no doubt aware, global gas prices are based on too many factors to be controlled through domestic production, and this project will not add to the gas supply in the near term.

In contrast, investment in renewables will favorably affect gas prices by decreasing the demand for gas from power generation, as explained by the World Resources Institute (https://www.wri.org/insights/why-renewable-energy-solution-high-prices).

While the Biden administration has taken admirable steps in the promotion of renewables, they must not undercut their results by allowing needless expansion of oil and gas infrastructure, while also causing massive disruptions and hardships to Arctic communities and ecosystems, who are already under severe strain from the impacts of climate change.

President Biden, BLM staff, you MUST say no to the Willow project this summer.

Letter 2: Against New Offshore Drilling Leases.

I’m writing to urge you to prevent new offshore drilling leases.

President Biden has already taken the admirable step of committing to a 50-52% reduction in GHG emissions by 2030 and net-zero emissions by 2050 as a part of the US Nationally Determined Contributions, and issuing an Executive Order on January 27, 2021 to place the climate crisis at the forefront of this Nation’s foreign policy and national security planning.

Any new oil leases will place the fulfillment of these promises out of reach.

The International Energy Agency (IEA) issued a report (https://iea.blob.core.windows.net/assets/deebef5d-0c34-4539-9d0c-10b13d840027/NetZeroby2050-ARoadmapfortheGlobalEnergySector_CORR.pdf) stating that pathways to net-zero by 2050 include NO new investment in oil and gas. New offshore drilling leases can lock-in long-term fossil fuel infrastructure that’s inconsistent with our efforts to solve climate change and pose huge risks to the health of communities, workers, and wildlife.

Additionally, new leases will do nothing for decreasing gas prices. Rising gas prices are a real and burdensome problem for families, caused primarily by global markets and shameless price-gouging by producers. The oil and gas industry is currently trying to exploit Russia’s unjust invasion of Ukraine by making a call for new drilling that they claim will lower prices.

But in reality, offshore drilling leases take years before they produce any oil, so they do nothing to bring down the price of gas at the pump today.

In contrast, investment in renewables CAN favorably affect gas prices by decreasing the demand for gas from power generation, as explained by the World Resources Institute (WRI, https://www.wri.org/insights/why-renewable-energy-solution-high-prices).

While the Biden administration has taken admirable steps in the promotion of renewables, they must not undercut their results by allowing needless expansion of oil and gas infrastructure, while also causing massive disruptions to vital coastal ecosystems, increasing the risk of dangerous oil spills, and negatively impacting Americans’ enjoyment of the ocean.

We constituents are counting on President Biden to seize the historic opportunity to lead the way to an equitable and just clean energy future by finalizing an offshore drilling plan that removes the lease sales in this draft plan and ultimately offers no new leases.

We must put in policies today that will help limit the warming of the earth for decades to come and center frontline and coastal communities who already bear the brunt of climate change burdens. We will continue to fight to ensure there is no new leasing in the final Five Year Plan in line with what science (as demonstrated by the IEA and WRI) and justice require.

Letter 3: In Favor of Using Executive Powers for Climate Action.

As your constituent and a supporter of the League of Conservation Voters, I want you to know that climate change is my top voting priority. Climate change is an unprecedented emergency, and must be treated as such. Conventional, incremental action will not do.

Our government must listen to the thousands of scientists and experts around the world — not to mention tens of millions of climate voters like me — and take immediate, transformational action to prevent widespread global destruction, displacement, and loss, using every possible lever within the Executive Branch.

President Biden has already taken the admirable step of committing to a 50-52% reduction in GHG emissions by 2030 and net-zero emissions by 2050 as a part of the US Nationally Determined Contributions, and issuing an Executive Order on January 27, 2021 to place the climate crisis at the forefront of this Nation’s foreign policy and national security planning.

However, there is a narrowing window for the government to take action to keep the fulfillment of these promises within reach.

The International Energy Agency (IEA) issued a report (https://iea.blob.core.windows.net/assets/deebef5d-0c34-4539-9d0c-10b13d840027/NetZeroby2050-ARoadmapfortheGlobalEnergySector_CORR.pdf) stating that pathways to net-zero by 2050 include NO new investment in oil and gas. 

For this reason, I call on you to immediately take action to block ALL new onshore and offshore drilling leases, since these leases will lock in emissions for decades to come, with no appreciable benefits. (These leases will not alleviate the current high gas prices, which are primarily caused by shameless and opportunistic price-gouging by oil producers.)

Additional necessary measures are: to require carbon capture from power plants and other major emitters of climate pollution, place strict limits on air pollution to safeguard all communities, strengthen standards for cleaner cars and trucks, protect communities from methane, conserve our public lands and waters, and declare a climate emergency, among other actions.

Furthermore, investment in renewables WILL help in by bringing down gas prices for families, since it will decrease the demand for gas from power generation, as explained by the World Resources Institute (https://www.wri.org/insights/why-renewable-energy-solution-high-prices). 

While the Biden administration has taken admirable steps in the promotion of renewables, including in the Executive Actions of July 21, 2022 this one avenue of investment is not sufficient.

I’m looking to you, President Biden, to rise to this historic occasion and keep your pledge to cut planet-warming emissions in half by 2030 and move swiftly on all possible executive climate solutions. 

Multiproject Update: End of Q2 and Start of Q3 of 2022.

I last made a multiproject update post here, listing my goals for Q2. 

I gave myself two extra weeks after Q2 officially ended, because the end of the month was chaotic-good. I went to Portland for the WDS conference in late June, and I had a huge dip in productivity right before it (because I hadn’t traveled in a while and was stressed) and a huge boost in productivity right afterward (because Portland is awesome). When July rolled around, I was still in the thick of my projects and didn’t want to stop work abruptly. 

Now that my extended quarter has ended, here is the latest on my big projects:

Research Quest

My reading line up for the quarter included a few big reports:

  • The SEC’s proposed climate disclosure rule (March 2022)
  • New IPCC report AR6, from three working groups – 1, 2, and 3 (2021-2022). Especially prioritizing Working Group 3, which focuses on Mitigation.
  • October 2021 report from the International Energy Agency (IEA) about Curtailing Methane Emissions from Fossil Fuel Operations.
  • FTC 2012 Green Guide

Of these, I was able to skim all of them (excluding the working groups 1 and 2 of the IPCC report). 

I spent a bunch of time on the SEC climate disclosure because I wanted to write a public comment in support of the rule.

When government agencies propose new rule, they often open a public comment period when we, the public, can share our views on it. They post all the comments they receive publicly on their website.

I’d never done this before, so I followed the guidelines from the Public Comment Project, and squeaked my email in just before their extended deadline of June 17th. I was worried I had bungled the submission because I didn’t see my comment on their public comments page, and I still might have, but according to this article it typically takes a month or two before the comments are posted. So I’ll be keeping my eye on that page to see if I did it right. I definitely want to keep doing these in the future, because it’s an effective way to influence climate policy. (If you want to read my comment, I’ve appended it at the end of this post!)

For the other three reports, I’m mostly stashing them away as references for future blogging. I’m still formulating what I want to say about them. I’m sure the FTC Green Guide will feature heavily in a planned deep dive into the subject of greenwashing.

The rest of my research lineup consisted of:

  • UNEP Six Sector Solution
  • Inconspicuous Consumption by Tatiana Schlossberg
  • Speed and Scale by John Doerr
  • Braiding Sweetgrass by Robin Wall Kimmerer
  • Web Survey (of useful websites for climate and sustainability data)

I mades some good headway into the first and last of these, and they will fit into a YouTube series I’m working on. So, once more, I’m stashing them away for when I need them. The middle three are books, and unfortunately, I didn’t get to them at all. I’m looking forward to some cozy reading time, so I’m rolling those into this quarter.

In the two research quests I’ve done so far, I organized the quest by the reports. I read each as thoroughly as I could and blogged about them. This was a pretty good way of working. I wanted to be thorough and feel like I knew what I was talking about. But it was also kind of a slow and lumbering process.

Going forward, I might shake up the research quest format a bit, so I can respond more quickly to current events. More on that soon.

YA fantasy novel

In the fiction world, I had two goals. One was to finish the ‘long draft’ of my YA fantasy novel by pasting into the main manuscript scenes that I’d written in various note-taking apps. I’m about halfway through this task, so I might give myself another couple of days to get this done before I set myself a new goal.

My second goal was to finish sharing my novel’s (real-world) backstory, so that you’d be all caught up when I started sharing real-time writing updates. I did manage to catch up to the start of this year by adding two new installments to the story. One more installment should get us to the present day.

Art and Painting

This is the one category where I crushed my goals, which were:

  1. To upload my recent watercolors and vector art into galleries in my Painting category.
  2. To make vector drawings of all the plants (and fruit and vegetables) in my house.

The Painting category of this blog is all the way up-to-date, and the vector drawings of plants are here, where you can download them in the form of a PDF booklet if you like. And you can watch the ‘making-of’ videos here, if you like drawing videos.

* * *

It’s been an intense quarter and a very, very mixed bag. I feel good about my progress, but also a need to adapt how I work, because there is a need for rapid action in preparation for the US midterm election.

 How about you? Did you have any projects planned for last quarter, and do you have any planned for this one?

The comment I submitted to the SEC (A few years ago, I used to sound this formal in my writing all the time! Can you imagine?):

To whom it may concern,
Thank you for the opportunity to comment on the proposed rule The Enhancement and Standardization of Climate-Related Disclosures for Investors.
I am Deepti Kannapan, an aerospace engineer with an Engineering Design background. I have a Master of Science degree in mechanical engineering from the University of California, Santa Barbara.

I strongly support this new rule, and welcome the prospect of clearer and more standardized climate-related information from companies whose disclosures have, thus far, been opaque and overly self-congratulatory.

I consider climate risk to be related to a measure of a registrant’s unused opportunities for GHG mitigation. For example, a company in a relatively easy-to-decarbonize industry that fails to take decarbonization efforts may face more customer backlash (and risk) than a company in a hard-to-decarbonize industry that makes use of best available practices. (Even though the latter company may have higher emissions overall.) 
I believe the proposed disclosures will provide useful information for making those comparisons. However, I have two comments:

1. Regarding the Request for Comment #111, I think GHG intensity should be specified per unit of production, broken out by product category.  I would consider a company with higher GHG intensity (than its peer companies) in a particular product category to have higher risk.

For example, for a company that produces both physical products and web services, I would compare its GHG intensity for physical products with other companies that produce those products, and compare its GHG intensity for web products with other web companies.

Comparing the aggregate GHG intensity across all product categories may not accurately reflect which company has more unused opportunities for GHG mitigation, since products and industries vary widely in their difficulty to decarbonize.

2. In addition to GHG intensity, I would like to know how dependent a registrant’s business model is on high sales volumes and wasteful design practices like planned obsolescence. A company that produces products with shorter life cycles and (resultant) higher sales volumes than its competition (such as ‘fast fashion’ or cheap electronic products) has more unused opportunities for GHG mitigation, even if its GHG intensity may be lower.

However, I would consider this company to have higher climate risk, since its business model may not be viable under future regulation or market pressure to pivot to more durable products. For this reason, I would suggest that a measure of product durability be added to the disclosure.
Please see below for relevant literature.
Thank you.
Sincerely,Deepti Kannapan

M.S. Mechanical Engineering, UC Santa Barbara,

B. Tech and M. Tech Engineering Design, Indian Institute of Technology, Madras

 * * *

Bibliography:– Rivera, Julio L., and Amrine Lallmahomed. “Environmental implications of planned obsolescence and product lifetime: a literature review.” International Journal of Sustainable Engineering 9.2 (2016): 119-129.
– Peters, Greg, Mengyu Li, and Manfred Lenzen. “The need to decelerate fast fashion in a hot climate-A global sustainability perspective on the garment industry.” Journal of cleaner production 295 (2021): 126390.

A “Quick” Backstory for My Novel, Part 3

If you’re new, please check out part 1 and part 2 of this story.

June-October 2021: I was pretty much not working on my novel at all, because I was stuck. There were other projects that needed my attention as well, mostly nonfiction. 

November-December 2021: This is when I started slowly coming unstuck. This whole period was a busy blur, but here are the main factors that helped unstick me.

Research

I spent most of my time during the gap organizing my notes and streamlining my research process for blogging. These were the two aspects of all my projects that consistently got me stuck. I’d collect and produce so much material that I couldn’t wrap my head around them.

Out of necessity, I caught up on indexing all my physical notebooks and file cabinets, and collected all my digital notes into a Notion database. It made a huge difference in being able to find the right notes when I need them, and forget about them the rest of the time.

Media and Inspirations

The other thing I did during the gap was reading and watching a lot of media, both in my genre and outside it. This was another recommendation from my developmental editor, but I hadn’t found time to do it. I watched a few old favorites like Monsters Inc, and read The Fifth Season and the Winternight trilogy for the first time. I got pretty intensely into Hamilton.  

Reading and watching these stories after spending months thinking about plot changed the experience. I could get engrossed in the story as I always did, but especially on rewatchings, I also started noticing details of how the authors structured the scenes and set up interesting conflicts early in the story.

Noticing the underpinnings was exciting, like I was in on the secret! These lessons made writing in my novel feel achievable again.

Working Out of Order

Since my my novel was on my mind again, I started watching YouTube videos on writing craft.

One in particular, Abbie Emmons’ video about how she organizes her Scrivener project caught my interest in particular. The way she set up her project to include the manuscript, research, inspiration, playlists, character profiles, etc, reminded me of my research organization system in Notion. 

An approach I could take to worldbuilding became clear to me. I’d make a database, like the one I used for research. Instead of collecting links and notes, I’d collect pages with brief backstories or descriptions of every element of my story world. 

I’m not sure why it took so long to figure out that what I’d been doing in May, trying to go strictly in order by finishing my current draft before attempting more worldbuilding, wasn’t working at all.

I think part of the trouble was that  I didn’t know how to tackle the questions, and I kicked the can down the road to avoid them. I’d rather struggle through my current draft instead. Even though there were dissonant world elements getting in the way of the story and I knew I needed to figure them out.  

Something about this parallel structure of the worldbuilding database, where I could write many short files instead of one long description, finally brought the worldbuilding side of the project within reach.

I’ve heard a lot of advice or warnings against getting too bogged down in world building, because it seems to be a common pitfall among fantasy writers to endlessly generate backstory, lore, and magic system information, at the expense of actually building a story. I think this is true for some, but it turned out I had the opposite problem. 

Worldbuilding

With this inspiration in hand, I made a bunch of Notion pages for research, world building, plot threads, and jumped between them with abandon.

Since I’d gotten better at research for my blog posts, it made the research for fiction that much easier. Researching for fiction is much ‘softer’. I don’t need to analyze and fact-check endlessly. All I need to do is find interesting material that sparks my creativity. 

In my worldbuilding database, I created elements of the world and wrote a very short passage about each of them, just enough that I had my impressions offloaded out of my head and ready to develop. Freeing up some working memory was a huge relief and let me explore further, covering more ground. The material I’d already created sparked ideas constantly, both when I was looking at the database and when I was wandering the house, making coffee, or sitting on the patio. 

All of the notes and research helped me create a richer, more textured, populated, and atmospheric world. At some point, the elements clicked together abruptly, and I was suddenly ready to analyze the plot. And then I was ready to draft. Because I’d done just enough behind-the-scenes work to feel ready.

 When I went back to rewrite my scenes, I could imagine the setting, social dynamic, and conversation much more vividly. The dissonant elements that kept pulling me out of the story were gone. It made a huge difference in being able to drop fully into a scene and let my imagination run wild while I wrote it.

These successes were more validation that I was figuring out my process. Learning to write this novel felt agonizingly slow and painful in places, and the jumping around between story elements felt risky, so I was glad to see it pay off in rapid writing progress.

To be continued.

A “Quick” Backstory For My Novel, Part 2

Here’s the continuation of my novel’s backstory. ‘Backstory’ in the sense of how, in real life, my novel came to be. Part 1 of the story is here. I left off at where I’d written my first (typed) draft with the novel writing group.

September 2020: I was finished my first (typed) complete draft. It was around 50k words, and I was pretty excited because I’d never before written anywhere near as much in a single project.

I had a ton of momentum going but nothing left to write because I’d reached the end! Also, the story was sharpening in its details and becoming more real to me.

In preparation for working with a developmental editor, I immediately went back and did some cleanup. My writing was in many different files and needed stitching together. (Interestingly, I’m in a similar phase now, in July 2022, on a later draft. I guess I just like writing in a ton of different files.)

October 2020: I worked with a developmental editor to analyze the story structure, map out all the scenes, ponder their purpose, and strengthen them. This was hugely helpful, and I had clear next steps. My editor’s recommendation was to go about making the rewrites, methodically, starting with Act I.

I’m not sure how long I spent, but I made spreadsheets and identified changes. I came up with a plan where I’d make multiple passes through the story, each time focusing on a different aspect. Such as the character arcs, world-building, and pacing.

February-April 2021: I signed up with my novel-writing group again for the second draft. I felt ready. The jumble of scenes had clicked into place within well-defined, coherent sequences that built to their own mini climaxes.

The sequences finally clarified, for the first time, how these mysterious things called plotting and pacing worked.

For the second draft, I was expected to post chapters in the writing group for review, and provide feedback to other writers. I wasn’t sure how this was going to fit with my multi-pass approach, where I only wanted feedback on the specific story-aspect I was working on. I got bogged down in trying to fit the structure of the class with how I seemed to work, intuitively. 

I ended up deviating from my plan and strengthening the first few chapters in more ways than I’d intended. 

Overall, the effect was that I didn’t come anywhere close to finishing my draft in the prescribed time, but the first chapters became a lot stronger. And my fellow-writers seemed to resonate with some of the characters, which felt pretty nice. No one had met my characters except me, till then.

May – November 2021: I had a more polished draft of a few of the ‘sequences’ that made up my novel, and many more to go. I had a much better sense of how to structure a sequence and make it exciting (to me, anyway). 

But I started getting stuck again, and I wasn’t sure why. For the next sequence, I needed a lot more clarity on my fictional world. But I’d been planning to do a full pass on character arcs before worrying about worldbuilding questions. I kept struggling through and tried to keep drafting so I could be done with this pass. 

I was constantly torn about what aspect of the project to work on. There were questions about the worldbuilding that were really bugging me and pulling at my attention. But I wasn’t ‘allowed’ to worry about that until I fixed what I was currently working on. Which I couldn’t – not confidently, anyway, because it depended on a world building question. After going in circles on this for a while, my momentum fizzled out, and I stopped working on the novel for nearly five months.

To be continued.

Line Drawings of Houseplants

Polishing up my drawings from the 10 Day Challenge!

Click on each image to see it zoomed in!

As I’ve mentioned, in May I drew (and YouTubed) a houseplant every day for 10 days! It’s been cool looking at the pile of art I made in a relatively short time. Recently, I spent some time polishing and designing the pictures into an arrangement I found pleasing. Now, I’m working on framing and hanging them on my walls.

I’ve collected the designed versions into an art book. If you’d like a copy (which you can use for any non-commercial purpose), you can get it for free here:

.