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Viewing recent projects in Natural Resources
  • Comments to BLM on Draft SEIS for Willow Master Development Plan

    In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect because BLM failed to account for several important environmental considerations, and in June, BLM released a draft supplemental environmental impact statement that improves upon the agency’s analysis and now finds that the Project will cause billions upon billions of dollars in climate damage. We submitted comments recognizing the significance of those climate damages and arguing that BLM continues to undervalue climate costs while overvaluing economic benefits.

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  • The Public Interest Review for LNG-Related Authorizations Cover

    The Public Interest Review for LNG-Related Authorizations

    After a meteoric rise in production over the past decade, the United States has become the largest exporter of liquefied natural gas (LNG) in the world. Yet, the analysis behind LNG terminal and export approvals overlooks climate and environmental justice impacts, despite promises of imminent reform. Policy Integrity’s new report provides a comprehensive look at the Department of Energy’s (DOE) and the Federal Energy Regulatory Commission’s (FERC) past practice in this space and offers recommendations for improving their review of the climate and environmental justice impacts of LNG approvals.

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  • Comments to DOE on Supplemental Environmental Analysis for Alaska LNG Project

    After the Department of Energy published a supplemental environmental impact statement claiming that exporting liquefied natural gas from a proposed Alaska terminal would decrease greenhouse gas emissions, we submitted comments challenging the Department’s methodology and assumptions. In particular, our comment letter explains that the Department’s analysis unreasonably assumes that the Project would merely displace existing exports from Gulf Coast facilities, and thus overlooks the inevitable economic reality that the Project will increase total natural gas supply and consumption. As our comment letter explains, courts have rejected this “perfect substitution” assumption in related contexts. Moreover, our letter explains that the Department’s lifecycle analysis insufficiently considers the choice of destination countries and is inconsistent with the agency’s analysis of economic impacts.

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  • Comment Letters on FERC’s Proposed Policy Statements for Natural Gas Infrastructure

    In February, the Federal Energy Regulatory Commission released two policy statements that acknowledged the Commission’s role in shaping the nation’s transition to a low-carbon future and called for the consideration of climate impacts in pipeline certificate proceedings. Today, the Institute for Policy Integrity filed two comment letters to these proposed policy statements.

    In one of our comment letters—filed jointly with over two dozen legal scholars from institutes across the country—we rebut arguments from opponents of the policies that the Commission lacks authority to consider climate effects in its oversight of natural gas infrastructure under the Natural Gas Act.

    In our other comment letter, we explain that the policy statements serve as an important step toward ensuring that upstream and downstream emissions are properly considered in line with the Commission’s statutory obligations, but provide several suggestions for improvements.

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  • Comments to FERC on Regional Energy Access Expansion Project DEIS

    Today we submitted comments to FERC on the draft environmental impact statement for Transcontinental Gas Pipe Line Co.'s Regional Energy Access Expansion Project. These comments offer recommendations for improving the Commission's assessment of climate and environmental justice impacts of the project, and its consideration of alternatives.

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  • Comments to FERC on Iroquois Gas Certificate Order

    Today we submitted comments to FERC regarding its decision to grant a certificate of public convenience and necessity to Iroquois Gas for its Enhancement by Compression Project. These comments begin by underscoring the Commission's obligation to independently review and scrutinize lifecycle greenhouse gas emission reports (or other evidence regarding net emissions associated with a project) submitted by applicants. The comments also highlight flaws in Iroquois' analysis which undermine the conclusion that the project will result in a decrease of emissions. The Commission overlooked these flaws in relying on the analysis to conclude the project would result in a net reduction, such that it need not further assess the project's climate impacts.

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  • Comments to DOE on CP2 LNG’s Export Application

    Policy Integrity filed comments on Venture Global CP2 LNG's application to the Department of Energy (DOE) for authorization to export liquefied natural gas (LNG) to non-free trade agreement nations. We argued that in line with relevant case law, DOE must consider the indirect greenhouse gas emissions associated with the CP2 LNG project in its National Environmental Policy Act (NEPA) review, and weigh the impacts in its Natural Gas Act Section 3 assessment. In doing so, DOE should apply reasonable assumptions to quantify indirect greenhouse gas emissions and better analyze substitution impacts from LNG exports. Furthermore, DOE should refrain from applying its recent NEPA categorical exclusion rule to the CP2 LNG project due to severe legal deficiencies with that rule. Finally, we urge DOE to work with FERC on a single NEPA review for the project because DOE and FERC's Section 3 authorizations are connected actions under NEPA.

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  • Comments to BLM on Supplemental Environmental Impact Statement for Willow Master Development Plan

    In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect, concluding that BLM’s analysis was deficient and failed to account for several important environmental considerations. With BLM now reopening its environmental review, we submitted comments calling on the agency to bolster its assessment of the Plan’s greenhouse gas emissions and economic need. Our comments, jointly filed with six other environmental groups, largely echo arguments from comments that we submitted when BLM was previously reviewing this proposal in 2019.

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  • Reforming Pipeline Review Cover

    Reforming Pipeline Review

    Taking a Closer Look at the Need for New Natural Gas Infrastructure

    The Federal Energy Regulatory Commission (FERC) uses a flawed process to evaluate the need for new, long-lasting gas infrastructure such as interstate pipelines, resulting in a certification process that fails to serve the public interest. As FERC begins to re-examine its approval process for new natural gas infrastructure, our report analyzes the Commission’s authority to consider a broader range of factors when deciding whether a proposed project is in the public interest. The report offers four key recommendations for reform.

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  • Comments to EPA and Army Corps of Engineers on Proposed Revised Definition of “Waters of the United States”

    The Environmental Protection Agency and Army Corps of Engineers recently proposed a rule to return to the pre-2015 definition of the term “waters of the United States” under the Clean Water Act. We submitted comments encouraging the agencies to more fully elucidate the benefits from the proposed regulation, as the current economic analysis understates the rule's positive environmental effects.

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