Comments on FERC’s NOI on the Certification of Interstate Natural Gas Pipeline Facilities
In April 2018, the Federal Energy Regulation 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. In the nineteen years since FERC’s existing policy statement was released, there have been significant advances in the understanding and measurement of climate change and other environmental effects of natural gas production, transportation, and consumption. Our comments suggest clarifications and improvements to FERC’s NEPA and Natural Gas Act analyses that will better inform policymakers and the public about the environmental effects of proposed projects.
We also submitted joint comments on the appropriate use of the social cost of carbon in the interstate natural gas facilities certification processes, including why and how greenhouse gas emissions should be monetized in FERC’s NEPA and Natural Gas Act analyses.