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After FERC policy shift, Northern Natural adds GHG data on project, seeks action


Adds downstream estimates for Northern Lights 2021

Requests FERC action to meet November in-service date

Suggests emissions 'not significant,' details avoidance

In light of the Federal Energy Regulatory Commission's policy shift on climate considerations in its natural gas project decisions, Northern Natural Gas has bolstered the greenhouse gas emissions information it has provided for a project nearing a commission decision point.

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In a March 22 order on Northern Natural's South Sioux City to Sioux Falls A-line Replacement Section 7 Project, FERC for the first time considered the significance of a gas project's impact on climate change (CP20-487).

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The pipeline company now has supplied more information, including estimating downstream GHG emissions, in relation to a separate pending project, Northern Lights 2021, and is asking FERC to promptly issue the certificate (CP20-503). That project is among a handful that received their environmental reports from FERC staff in 2020 and are awaiting a final decision. Backers of a larger project, the 250 MMcf/d, 92.5-mile North Bakken Expansion project, have on several occasion pressed FERC to act (CP20-52).

"Time is of the essence to begin construction ... to meet the in-service date of November 1, 2021," Northern Natural said in an April 28 letter asking FERC to issue an order.

The project entails a new compressor station, additional compression at an existing station and short segments of pipeline and other modifications, all in Minnesota, increasing capacity by 45.6 MMcf/d.

As Northern Natural noted, FERC, in the prior March order altering its climate approach, took the total estimated GHG emissions in tons and compared that amount to the total US emissions, finding the impacts were not significant.

Northern Natural said that using that same method, total construction and operational GHG emissions for its pending Northern Lights 2021 project are within the same order of magnitude and are, therefore, "not significant."

Downstream emissions

The company also gave FERC new estimates of downstream emissions associated with the project, relying on a report of a third-party consultant. The consultant estimated that Northern Lights 2021 project's downstream emissions would fall within a range of an initial amount of 9,768 t/year to up to 259,334 t/year, assuming current load factors continue. But Northern Natural suggested it is unlikely current load factors will continue in the future, given programs in place and under development to achieve GHG emissions reduction in Minnesota and nationally.

"Comparing the estimated downstream GHG emissions from the project to the 2019 national GHG emissions of 6.558 billion metric tons, adjusting for the metric conversion, the project's downstream GHG emissions represents a 0.00014% to 0.0036% increase in GHG emissions, an increase that is of similar magnitude to emissions the commission concluded were 'not significant' in the March 22 Order," Northern Natural said.

Emissions avoidance

Northern Natural's additions to the Northern Lights 2021 application also appear to respond to FERC Chairman Richard Glick's suggestions that companies might address climate concerns through mitigation.

In its April 28 letter, the pipeline developer highlighted steps during the project planning that it said "contribute to GHG emission avoidance."

The use of hot taps and line stops avoids releasing 10.2 MMcf of gas, or 5,783 mt of CO2e, it said. The project scope was also reduced because one shipper sought alternatives to gas supply, avoiding an estimated 10,000 mt of CO2e, it added.

The company's estimate presumes less than full capacity utilization, reflecting varying demand requirements, Northern Natural told FERC.

It sought to make the case that the project balances the need to secure energy for its shipper's customers alongside carbon reduction goals of the state and local community. For instance, it pointed to partnership two of the project's largest shippers, CenterPoint and Xcel Energy, have with the City of Minneapolis to reach its climate goals.

"Even as our Minnesota customers work toward these carbon-reduction goals, they responsibly and prudently retain a focus on their customers' energy needs," the company wrote.

Of note, amid some blowback about FERC's decision to shift its climate approach in the context of a small order, FERC does not appear to face a challenge in that docket. Northern Natural has accepted the certificate for the South Sioux City to Sioux Falls A-line Replacement Section 7 Project, and despite a late intervention Enbridge Gas Pipelines, there has not been a request for rehearing of the order that included the policy shift.