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Amicus Brief on Climate Impacts of the PennEast Pipeline Project

In January, the Federal Energy Regulatory Commission (FERC) authorized the construction and operation of the PennEast Pipeline Project, a 116-mile natural gas pipeline between Pennsylvania and New Jersey and associated facilities. FERC’s Environmental Impact Statement (EIS) showed that the project will result in an increase in greenhouse gas emissions but did little more than quantify those emissions, failing to fully analyze and consider the climate impacts of the project. We submitted an amicus brief to the U.S. Court of Appeals for the District of Columbia Circuit that demonstrates how FERC could have used the Social Cost of Carbon to analyze the pipeline’s climate impacts.

Our brief explains that the Social Cost of Carbon is a widely-accepted tool to monetize climate impacts and shows that FERC would have found the climate damages of the project to be over $1 billion each year. We further argue that FERC’s reasons for rejecting the Social Cost of Carbon were inconsistent with its own description of the tool’s purpose and use, with the consensus of experts, with the practice of other federal agencies, and with FERC’s choices to monetize other effects. Given the availability of this widely-accepted tool, FERC’s failure to contextualize and assess the significance of the PennEast Project’s climate impacts was arbitrary.