Comments to FERC on the Southeast Market Pipelines project supplemental EIS
We submitted comments to the Federal Energy Regulatory Commission (FERC), along with partners, on the Commission’s failure to use the social cost of greenhouse gases in the Southeast Market Pipelines Project supplemental environmental impact statement. These joint comments begin by offering a detailed rejection of FERC’s arbitrary and misleading rationale for failing to use the social cost of greenhouse gases, then go on to offer additional guidance on how to monetize climate effects consistent with the currently best available science and economics—specifically, by selecting a central estimate of global damages using a 3% or lower discount rate. We note that, notwithstanding a recent Executive Order disbanding the Interagency Working Group (IWG) on the Social Cost of Greenhouse Gases, the estimates updated by that group in 2016 are still appropriate estimates of the lower bound of the social cost of greenhouse gases, reflecting current best practices and best scientific and economic literature. We further stress that any departure from those estimates would require agencies to engage with the complex integrated assessment models and ensure consistency with the most current scientific and economic literature, which overwhelmingly supports a global estimate based on a 3% or lower discount rate.
In addition to the joint comments, we submitted an another set of comments on the Southeast Market Pipelines project supplemental EIS. Because FERC did not conduct a full assessment of substitute energy sources, we argue that FERC should analyze the effects of approving the project on natural gas supply and prices, the consequential effect on the demand for natural gas, and the ultimate effect on downstream greenhouse gas emissions.