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Comments to FERC on the North Baja Xpress Project

The North Baja XPress Project would provide a significant increase in natural gas compression and transportation, potentially resulting in 9.5 million metric tons or more 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.

In our August 2021 follow up letter responding to FERC's draft environmental impact statement for the project, we note that the Commission has taken the helpful steps of quantifying direct and downstream emissions, but should still quantify upstream emissions, assess the project's incremental environmental harms, and consider avenues to mitigate emissions.