Comments to FERC on Failure to Monetize Climate Effects of Riverdale Gas Pipeline
We recently submitted comments to the Federal Energy Regulatory Commission on its environmental assessment (EA) for the Rivervale South to Market pipeline project in New Jersey. Once again, FERC quantified the tons of downstream greenhouse gas emissions that the project would generate, but the Commission did not use the social cost of greenhouse gases to monetize the climate effects of those emissions. In the EA, FERC incorrectly claims that it is impossible to determine the significance of a discrete amount of additional greenhouse gas emissions. Our comments dispel FERC’s arbitrary and misleading rationale and explain why failing to meaningfully analyze a project’s climate effects violates NEPA. Our comments also offer guidance for how the Commission should use the social cost of greenhouse gases metric based on the best available science and economics going forward.