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24 Aug 2021 | 19:25 UTC
By Maya Weber
Highlights
Finds FERC staff upper bound estimates 'unrealistic'
Offers average utilization rate to back finding on significance
EPA pushes upstream estimate, social cost of carbon
Tennessee Gas Pipeline offered the Federal Energy Regulatory Commission what it called a "more realistic" estimate of greenhouse gas emissions associated with its East 300 Upgrade Project, applying an average utilization rate, as debate continues over a new approach to considering climate impacts at the commission.
The proposed project, involving compression in New Jersey and Pennsylvania, would add 115,000 Dt/d of firm transportation capacity on Tennessee's 300 Line to provide firm service to Consolidated Edison of New York. It is among a handful of gas projects for which FERC is conducting supplemental environmental impact statements in order to help assess the impact on climate change.
FERC staff's June 9 draft EIS for the East 300 Upgrade (CP20-493) found that with the exception of climate change impacts, approval of the project, with the mitigation measures, would not result in significant environmental impacts. Staff was unable to determine significance with regards to climate change impacts.
But in comments Aug. 23, Tennessee argued that the full burn or upper bound estimate FERC staff included in the draft "overestimates emissions to the point of being useless to a reasoned analysis."
Tennessee offered its own, alternative analysis, noting that local distribution companies such as Con Edison are required to maintain enough pipeline capacity and storage volumes to satisfy peak-day demand. While the project is needed to enable Con Edison to lift its moratorium on new gas service hookups in Westchester County, Tennessee said that due to Con Edison's demand and emissions reductions programs and the potential for oil-to-gas switching once the moratorium is lifted, it is not clear the project will result in additional downstream emissions.
Rather than the full burn approach FERC has included, Tennessee recommended applying an average utilization rate of Tennessee's system, selecting Tennessee's Zone 5, which has a 77% utilization rate.
"As demonstrated by these calculations and comparisons, the direct and indirect emissions attributable to the project are minimal when compared to global emission levels and to the actual emissions inventories and stated emissions goals of the United States and each of the applicable states," Tennessee wrote. It concluded the emissions attributable to the project are "not significant."
It found the project's downstream emissions represent 0.70 % of New York's 2030 emissions targets and 2.81% of New York's 2050 emissions targets under the Zone 5 average utilization scenario.
Further, Tennessee said FERC should consider that the East 300 Upgrade Project is designed to support Con Edison's demand in accordance with New York's clean energy goals, and that FERC should consider steps Con Edison is taking to reduce emissions.
The US Environmental Protection Agency weighed in as well, registering "environmental concerns" with FERC's draft EIS, and urging FERC to assess upstream GHG emissions and to use the social cost of GHGs to disclose climate impacts. In contrast with Tennessee's approach, EPA urged FERC to omit percentage comparisons to national and state level emissions, stating that this could diminish the significance of incremental impacts. Rather than using a comparison to state goals, FERC could add a "qualitative discussion disclosing the increasing conflict over time between continued GHG emissions and GHG emissions reduction policy," said the comments from EPA's Region 2 office.
By applying the social cost of GHG estimates, EPA said the "projected operational and downstream emissions associated with the maximum additional end-use combustion that could result from the new gas transportation equate to approximately $120 million in climate damages per year."
Tennessee is not the only pipeline to argue that FERC's upper bound or full burn estimate, included in recent draft EISs, should not be used in determining the significance of climate change impacts of projects. Iroquois Gas Transmission System, in Aug. 9 comments, told FERC the Enhancement by Compression project (CP20-48) would have anticipated annual volume of gas sales equating to 25% utilization rate of the project capacity, even though the use may be much higher on limited dates of peak demand.
And Adelphia Gateway, in Aug. 9 comments on the draft EIS for the Market Hook Compressor Station (CP21-14), argued there is no reliable standard for determining the significance of GHG emissions for the project. Nonetheless, it made the case that the potential increase in CO2 equivalent emissions from the project is substantially lower than that from all but one of recently certificated projects with incremental capacity.