Underground Construction - May 2021 - 11

Commission had not established a " methodology " for weighing GHG emissions and,
secondly, that it already had issued a request,
called a notice of intent, asking for public
comment on the GHG issue and others.
Those comments weren't due until April 25.
" This order is likely to have profound
consequences, " he wrote. " I reiterate the
advice I have given to everyone who would
listen since the Commission's issuance in
Algonquin last month: every single natural
gas pipeline company, LNG company and
shipper should intervene in every single
certificate item. Start now. " Danly listed
50 projects that could be affected.
Enbridge Gas Pipelines has projects in
that group, either pipelines it owns outright,
such as Algonquin Gas Transmission, or
others it owns partially via a joint venture,
such as Sabal Trail Transmission, LLC.
P. Martin Teague, vice president, US Gas
Law at Enbridge, wrote to FERC on March
17, just before the order was formally
published: " Enbridge Gas Pipelines are
concerned about the possibility of industry-wide policy changes occurring in individual certificate dockets at the Commission.

Such policy changes have the potential to
apply generally to all natural gas industry
participants, and affect the natural gas industry as a whole and each of the Enbridge
Gas Pipelines individually in a manner not
contemplated in discrete proceedings. "
In assessing the Northern project, FERC
totaled up the GHG emissions likely to
be created by construction of the project
and compared them to national and state
emissions in the states (South Dakota and
Nebraska) the project will pass through. On
that basis, FERC found the GHG emissions
to be insignificant. What the commission
did not do was add in the GHG emissions
likely to be created " upstream " and " downstream, " in the first case, from the processing of the gas, and in the second, from
transportation and distribution of the gas.
" Future FERC projects may trigger a
more robust analysis ... such as where new
service is provided or if they take place in
states with GHG reduction goals/renewable portfolio standards, " said Auslander.
Northern was simply replacing existing
pipeline on an existing route.

The commission explained in its order:
" NEPA does not require that the studies,
metrics and models - scientific and otherwise - on which an agency relies be universally accepted or otherwise uncontested.
Instead, NEPA permits agencies to rely on
the best available evidence, quantitative
and qualitative, even where that evidence
has certain limitations. "
Danly differed, arguing, " Not only
does the majority decline to institute an
analytical framework, it does not even
establish a threshold above which it will
consider emissions to be 'significant' under
the standard it adopts.
" It is no standard at all, merely a black
box comparison of numbers the commission can apparently apply however it sees
fit on a case-by-case basis. In this case,
Northern Natural Gas Company luckily
passes. Other applicants, included in numerous cases currently pending before the
commission, must now guess whether their
own significant investments in critical infrastructure will also pass the commission's
ad hoc review. " *

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Underground Construction - May 2021

Table of Contents for the Digital Edition of Underground Construction - May 2021