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Comments to FERC on LNG Compression Project in New York

Iroquois Gas Transmission System’s Enhancement by Compression Project would provide a significant increase in natural gas compression and transportation, potentially resulting in over 2.4 million metric tons in downstream greenhouse gas emissions. The Federal Energy Regulatory Commission, however, failed to estimate the project’s total emissions and climate damages. In October 2020,  we submitted comments recommending that FERC consider the full range of upstream and downstream emissions and contextualize their impacts using the social cost of carbon.

We followed up with further comments in August 2021, noting that the Commission’s new approach to assessing climate impacts takes the legally required step of quantifying direct and downstream emissions, but fails to quantify upstream emissions, assess the project’s incremental climate harms, or consider avenues to mitigate its greenhouse gas contributions.