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Comments to FERC on Mitigation Technical Conference

We submitted post-technical conference comments to FERC regarding its authority to consider greenhouse gas emissions and to impose mitigation conditions in assessing whether to grant a certificate of public convenience and necessity for interstate natural gas pipelines and other infrastructure projects. Our comments supplement previously submitted comments to FERC regarding the Commission's authority and obligation to assess greenhouse gas emissions under the National Environmental Policy Act (NEPA) and the Natural Gas Act (NGA) and to impose conditions on a certificate requiring mitigation of greenhouse gas emissions. Our comments also recommend the Commission prescribe reasonable default estimates for calculating emissions, while placing the burden on the applicant or other stakeholders to provide accurate, comprehensive, and reliable project-specific information to deviate from those defaults. Finally, we recommend that the Commission monetize climate damages using the social cost of greenhouse gases to assess the project's climate impacts under NEPA and balance them against benefits under the NGA.