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Comments to FERC on Natural Gas Infrastructure

The Federal Energy Regulatory Commission (FERC) issued a notice of inquiry on how to revise its policy on certifying the construction and operation of interstate natural gas transportation facilities. We submitted comments recommending several ways FERC can improve its evaluation of environmental impacts and its methodology for determining whether there is need for a proposed project. In particular, we recommend that FERC:

  • Quantify direct, upstream, and downstream greenhouse gas emissions in all analyses.
  • Not use a complete substitution assumption in assessing emissions, as affirmed by recent case law.
  • Not assume zero indirect emissions for a replacement pipeline project, because by extending the lifespan of an existing pipeline, the replacement project causes both upstream and downstream emissions relative to the no-action baseline.
  • Consider requiring applicants to purchase carbon offsets to mitigate unavoidable greenhouse gas emissions of natural gas infrastructure as a condition of granting a certificate.
  • Consider need on a regional basis—drawing on its decision to identify and consider regional solutions in the electric transmission context—to ensure more efficient and cost-effective natural gas infrastructure is developed, to avoid overbuilding, and to prevent unjust and unreasonable natural gas transportation service rates.
  • Consider transition risk, including the combination of a shift to a decarbonized resource mix and building electrification, at the time of certification as part of assessing whether a pipeline is needed under the NGA.
  • Refine its analysis to better capture and assess impacts on environmental justice communities by using more granular census block data; using a broad comparison population in determining whether project’s impacts disproportionately affect identified communities; and considering all pollution impacts even when they do not exceed legal thresholds.

Additionally, we worked with a coalition of non-profit environmental groups to submit joint comments supporting FERC’s use of the social cost of greenhouse gases to assess climate impacts. As those comments explain, the social cost of greenhouse gases facilitates analytical rigor in assessing climate effects, compared to other methodologies that FERC has proposed.

These comments supplement our July 2018 comments on a previous FERC notice of inquiry.