Comments to FERC on a Natural Gas Project EIS
We recently submitted comments to the Federal Energy Regulatory Commission on a natural gas processing and storage facility and marine export terminal in Louisiana, the Calcasieu Pass Project. While the DEIS quantifies the tons of greenhouse gas emissions related to this project—almost 4 million metric tons of carbon dioxide per year from operations, plus hundreds of thousands of tons per year during construction—FERC fails to apply the social cost of greenhouse gas metric to fully account for the climate effects of these emissions. Once again, FERC resorts to flawed arguments used in other inadequate NEPA reviews to implicitly justify why the Commission chose not to use the social cost of greenhouse gases metric for the Calcasieu project. Our comments provide a detailed rejection of FERC’s arbitrary and misleading rationale for failing to use the social cost of greenhouse gases, and offer additional guidance on how to monetize climate effects consistent with the currently best available science and economics.