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Comments to FERC on Rio Grande Natural Gas Project

The Federal Energy Regulatory Commission (FERC) prepared a Draft Environmental Impact Statement (DEIS) for the Rio Grande LNG Project. Despite quantifying over 8 million metric tons of carbon dioxide-equivalent emissions per year from operations, FERC does not account for the climate effects of these emissions. We submitted joint comments that offer a detailed rejection of FERC’s arbitrary and misleading rationale for failing to monetize the project’s climate effects. We urge the agency to apply social cost of greenhouse gases estimates.

FERC’s analysis includes monetized effects like millions of dollars’ worth in tax revenue and payroll expenditures but does not offer a substantive discussion of the project’s specific climate effects. Failing to similarly monetize the climate costs of the project is inconsistent and arbitrary, depriving the public and decisionmakers of the information and context they need to weigh all of the project’s potential effects. We ask FERC to monetize climate impacts using the social cost of greenhouse gases and, specifically, select a central estimate of global damages using a 3% or lower discount rate.