Recent Projects

In July, the Bureau of Ocean Energy Management (BOEM) released its proposed five-year offshore leasing plan, which contemplates scheduling anywhere from zero to eleven lease sales over the coming half-decade. As part of that proposal, BOEM conducts a cost-benefit analysis in which it finds net benefits from offshore leasing, but recognizes uncertainty and specifically calls for comment on this analysis.

In response to this call for comments, Policy Integrity submitted two original reports offering extensive feedback on BOEM’s cost-benefit analysis. As detailed in those reports, BOEM’s analysis severely understates the costs of OCS leasing—particularly the climate costs. Our reports offer original analysis and modeling finding that, properly considered, the climate costs of offshore leasing alone may exceed the total benefits from that leasing.

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.

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.

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.

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.

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.