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Comments to FERC on Regional Energy Access Expansion Project DEIS

Today we submitted comments to FERC on the draft environmental impact statement for Transcontinental Gas Pipe Line Co.'s Regional Energy Access Expansion Project. These comments offer recommendations for improving the Commission's assessment of climate and environmental justice impacts of the project, and its consideration of alternatives.

On climate, the comments recommend that the Commission recognize that upstream emissions are reasonably foreseeable and quantify and assess the project's upstream emissions. The comments also recommend the Commission use the social cost of carbon to assess significance, noting that, based on the Commission's estimate of direct and downstream emissions, the project could result in $931 million in climate damages per year, and that upstream emissions could result in an additional $140 million in climate damages per year.

On environmental justice, the comments recommend that FERC (1) clarify the geographic range of expected air quality impacts and analyze impacts to all the affected environmental justice communities; (2) consider adverse health impacts on affected communities from pollution below the NAAQS; and (3) conduct an environmental justice analysis of project alternatives.

The comments also recommend that FERC properly analyze the no-action alternative and adequately review non-gas and non-pipeline gas alternatives.