FERC cannot foresee climate impact of Southeast gas pipeline
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October 03, 2017
FERC cannot foresee climate impact of Southeast gas pipeline

Five weeks after being ordered by the U.S. Court of Appeals for the D.C. Circuit to describe the “reasonably foreseeable” effects of greenhouse gas (GHG) emissions resulting from a natural gas pipeline project—or explain why it cannot provide such a description—the Federal Energy Regulatory Commission (FERC) has issued a brief Supplemental Environmental Impact Statement (SEIS) to comply with the court’s order. As it did in the Environmental Impact Statement (EIS), the SEIS repeats that operation of the pipeline will not result in a significant impact on the environment. FERC also states that it could not find a suitable method to attribute discrete indirect environmental effects to GHG emissions resulting from the project.

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Project complete and operating

The D.C. Circuit case (Sierra Club et al. v. FERC) concerns a challenge to the Southeast Market Pipelines (SMP) Project. The project, which is complete, comprises three separate but related pipelines totally 685 miles, which are intended to supply three Florida power plants with natural gas to meet the state’s growing demand.

In December 2015, and as required by the National Environmental Policy Act (NEPA), FERC issued its Final EIS (FEIS) for the SMP Project and, several months later, approved construction. In July 2017, FERC authorized the commencement of pipeline operation.

Shutdown requested

Plaintiffs in the case had petitioned FERC to stop construction. When FERC denied the petition, the plaintiffs asked the D.C. Circuit to rule on their contention that the FEIS was deficient because it failed to adequately consider the project’s contribution to GHG emissions and its impact on low-income and minority communities.

In its defense, FERC told the court it did not consider the project’s indirect impact on GHG emissions and climate change because it is impossible to know exactly what quantity of GHGs will be emitted as a result of its approval of the project. In a majority ruling, the court agreed with the plaintiffs and told FERC to expand its FEIS with a discussion of the significance of the indirect effect of GHG emissions from the power plants as well as the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions.

Blocked by ‘overwhelming complexity’

In its SEIS, FERC notes that the three power plants have the potential to increase GHG emissions from Florida’s fossil-fuel power plants by between 3.7 percent and 9.7 percent, with the latter figure representing an “unlikely upper bound.” FERC then said it could not find a suitable method to attribute discrete environmental effects to GHG emissions. FERC states:

“The atmospheric modeling used by the Intergovernmental Panel on Climate Change, Environmental Protection Agency, National Aeronautics and Space Administration and others is not reasonable for project-level analysis for a number of reasons. For example, these global models are not suited to determine the incremental impact of individual projects, due both to scale and overwhelming complexity. We reviewed simpler models and mathematical techniques to determine global physical effects caused by GHG emissions, such as increases in global atmospheric CO2 [carbon dioxide] concentrations, atmospheric forcing, or ocean CO2 absorption. We could not identify a reliable, less complex model for this task and we are not aware of a tool to meaningfully attribute specific increases in global CO2 concentrations, heat forcing, or similar global impacts to SMP Project GHG emissions. Similarly, the ability to determine localized or regional impacts from GHGs by use of these models is not possible at this time.”

The D.C. Circuit may yet rule on the adequacy of FERC’s explanation of why it cannot foresee the environmental effects of GHG emissions indirectly caused by the SMP Project.

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