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Amicus Brief in D.C. Circuit on Tennessee Pipeline Extension

If constructed, the Tennessee pipeline extension and related projects would be responsible for substantial greenhouse gas emissions. The Federal Energy Regulatory Commission’s (FERC) analysis disregards upstream and downstream emissions and, further, fails to analyze the context, intensity, or significance of the incremental climate damages they will cause. We submitted an amicus brief to the U.S. Court of Appeals for the D.C. Circuit that explains how FERC’s failure to quantify the project’s emissions and monetize climate damages using Social Cost of Carbon estimates is arbitrary.