The Federal Energy Regulatory Commission has produced an Environmental Impact Statement on this proposal declaring it acceptable.  The following comments were submitted to FERC in opposition to this conclusion.

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@ssocan.eco
541-500-2331
December 13 2022

 

 

Federal Energy Regulatory Commission

Chairman Glick and members of the Commission:

I write as cofacilitator of the organization and on behalf of the over 2,000 Southern Oregonians and friends who are Southern Oregon Climate Action Now (socan.eco). Our Mission is to promote awareness and understanding of the science behind the climate crisis while motivating individual and collective action to address it.  In service of this mission, we engage individuals in taking whatever steps they can to reduce emissions while we collaborate with legislators to promote state and federal programs and policies that will reduce emissions and increase greenhouse gas sequestration from the atmosphere. We recognize that individual action is a necessary but insufficient response to the crisis and that to achieve the needed emissions reduction urged by the Intergovernmental Panel on Climate Change, state and federal agencies must take whatever action they can to address the problem. This, obviously, is relevant to FERC since this commission has authority over energy proposals that can make the situation worse or can offer some remedy.

When federal agencies approve proposals that only make matters worse, they make a mockery of state efforts and individual efforts and undermine the future livability of our planet for our children and grandchildren, not to mention all life as we know it.

In its Factsheet, FERC states in terms of the Greenhouse Gas Emissions Threshold for consideration that:

“The Commission is establishing a rebuttable presumption that proposed projects with 100,000 metric tons per year of carbon dioxide equivalents (CO₂e) emissions will be deemed to have a significant impact on climate change.” As I will demonstrate below, the GTN Express project will result in many millions of tons of greenhouse gas emissions and thus clearly falls within the FERC guidelines of presumption of significant impact on climate change.

This same source also states:
“A project’s reasonably foreseeable greenhouse gas (GHG) emissions will be based on a projection of the amount of capacity that actually will be used, the projected utilization rate and any other factors impacting the quantification of project emissions.”

In addition, we learn that in Quantifying Greenhouse Gases:

“The Commission will follow CEQ regulations and quantify a project’s GHG emissions that are reasonably foreseeable and have a reasonably close causal relationship to the proposed action, including those effects that occur at the same time and place as the proposed action and effects that are later in time or farther removed in distance from the proposed action.”

In addition:
The Commission will:
Consider on a case-specific basis whether upstream emissions are a reasonably foreseeable effect of an NGA section 7 project.

Clearly FERC acknowledges the need to assess upstream emissions in some situations.

Then, in a statement of totally berserk contradiction to all the above, on p 4-44, we learn:
“As the Commission has stated in previous proceedings, the environmental effects resulting from natural gas production are generally neither caused by a proposed natural gas infrastructure project nor are they reasonably foreseeable consequences of our approval of an infrastructure project, as contemplated by CEQ regulations, where the supply source is unknown. Here, the specific source of the additional natural gas to be transported via the GTN Xpress Project is currently unknown and may change throughout the project’s operation. Accordingly, we affirm that the GHG emissions associated with upstream production of gas are not a reasonably foreseeable impact of this project.”

This is just unforgivable nonsense and displays a complete lack of integrity on the part of FERC in terms of acknowledging the greenhouse gas emissions that will inevitably result from the proposal if completed. The only way the FERC assertion could possibly be reasonable is if the Commissioners judge that the gas being pumped through the pipeline is conjured miraculously from thin air. This is exactly the kind of nonsense that undermines the credibility of FERC as a regulatory agency established to serve the public good.

If FERC members have any integrity, you will send the Environmental Impact Statement back for revision to reflect the fact that this pipeline poses an enormous threat to our climate. Rather than granting the proposal a free pass, in service to our planet and its occupants, FERC should be closing the entire pipeline.

GNT Express Greenhouse Gas Emissions estimation

I offer the following clarification of my conclusions:

The basic expectation for pipeline transmission are stated below:

According to Gonzalez (2022) The pipeline capacity is currently 2.7 bcf/d or 985.5 bcf/yr, the proposed expansion is 150 mcf/d or 54.75 bcf/yr . Together, these would achieve capacity of 2.85 bcf/d or 1.04025 trillion cf/yr. The percentage of natural gas that is methane is 70 -90% (Natural Gas Solution 2022), so I use 80%.
Regrettably, from extraction to consumption, the gas leaks, at the rate of 3.7% from the Permian Basin (Zhang et al, 2020). Furthermore, as a greenhouse gas, methane has a global warming potential much greater than carbon dioxide.

I use this information to compute the leakage rate of methane before expansion at 29,170,800,000.00

cu ft/year, increasing as a result of expansion by 1,620,600,000.00 cu ft annually to 30,791,400,000.00. cu ft annually. The conversion of a cubic foot of methane to weight at 0.042 lbs (EPA 2022) was then used to compute the weight of the methane, and then its weight in carbon dioxide equivalent terms.

The warming impact of the gas is computed on the basis that methane has a global warming potential much greater than carbon dioxide, identified as 82.5 times greater on a 20-year basis and 29.8 times worse on a 100-year basis (IPCC 2021, Table 7.15).  I will use the latter value. I then use these values to estimate the carbon dioxide equivalent leakage of methane and, later, the overall impact of the pipeline gas. Thus, the initial pipeline would be responsible for 36,510,173,280.00 pounds and 18,255,086.64 tons of Carbon dioxide equivalent emissions, the expansion will then add 2,028,342,960.00 pounds or 1,014,171.48 tons of CO2e emissions, and the final augmented pipeline will account for 38,538,516,240.00 pounds and 19,269,258.12 tons of CO₂e emissions annually.

This calculation is actually generous since the emissions are computed as a percentage of pipeline capacity, not the initially extracted gas since it’s at extraction that leakages start and presumably the amount extracted to achieve the stated pipeline capacity is greater.

To these totals we must now add the emissions that result downstream from the combustion of the transmitted natural gas.  According to EIA (2022) The rate of carbon dioxide emissions from burning natural gas is 120.96 pounds per thousand cubic feet.

Thus, the initial pipeline transmitting 985,500,000,000.00 cu ft annually, will result in 65,937,518.64 tons of carbon dioxide, the increase of 43,800,000,000.00 cu ft annually will result in 5,840,091.29 tons of CO₂ emissions, and the enhanced pipeline will transmit 832,200,000,000.00 cu ft annually and result in 110,961,734.53 tons of CO₂ emissions.

We must now add the methane leakage and combustion CO₂ emissions to produce the overall impact of this pipeline.  Thus, the original pipeline results in 65,937,518.64 tons of CO₂e emissions, the increased capacity adds 6,854,262.77 tons of CO₂e emissions including 5,840,091.29 tons of gas combustion emissions, a total far exceeding the statement “that proposed projects with 100,000 metric tons per year of carbon dioxide equivalents (CO2e) emissions will be deemed to have a significant impact on climate change.”  Finally, the enhanced pipeline will result in a total of 130,230,992.65 tons of CO₂e emissions annually.

It is unconscionable that FERC would allow such a project to go forth at a time when the nation as a whole, and especially the western states of Washington, Oregon, and California, are struggling to curtail their greenhouse gas emissions.  The annual emissions from this enhanced pipeline alone will be approximately twice the current total sector-based emissions of Oregon. If the Federal Government, of which FERC is a component, is serious about addressing the climate crisis, this travesty cannot be allowed to go forward.

We concur with the comments reported by Gonzales (2022) from the Attorneys General of Washington, Oregon, and California as they defended their states efforts to promote greenhouse gas emissions reductions:

“There is insufficient evidence the project serves a public necessity or the public interest,” the AGs said in comments to FERC. “Instead, the evidence indicates that existing customers will subsidize the expansion, and the project will primarily serve the interests of Canadian gas producers in gaining market share, not the needs of American consumers.”

The performance of FERC in this case, as in so many other cases, denies its responsibility to serve the public good rather than the short-term profits of one industry – especially the gas industry that has a track record of misinformation and disinformation about its product and the impact of its actions on our climate to promote its business model. On behalf of generations as yet unborn, and all life on the planet as we know it, we urge you to reject the EIS and demand an assessment that reflects reality as you and we know it is.

Respectfully Submitted

Alan Journet

EIA 2022 Carbon Dioxide Emissions Coefficients.  Energy Information Agency https://www.eia.gov/environment/emissions/co2_vol_mass.php

EPA 2022 How large would a pipe have to be to contain a threshold amount of methane? Unites States Environmental Protection Agency. https://www.epa.gov/rmp/how-large-would-pipe-have-be-contain-threshold-amount-methane#:~:text=Assuming%20a%20methane%20gas%20density,cubic%20feet%20at%2010%20atm.

Gonzalez L. 2022 TC’s GTN Expansion between Idaho and Oregon Progresses with Positive EIS. Natural Gas Intelligence, December 12, 2022. https://www.naturalgasintel.com/tcs-gtn-expansion-between-idaho-and-oregon-progresses-with-positive-eis/

IPCC, 2021: Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S.L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M.I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T.K. Maycock, T. Waterfield, O. Yelekçi, R. Yu, and B. Zhou (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 2391 pp. https://report.ipcc.ch/ar6/wg1/IPCC_AR6_WGI_FullReport.pdf

Natural Gas Solution 2022 What is Natural Gas? The Natural Gas Solution http://naturalgassolution.org/what-is-natural-gas/

Yuzhong Zhang, Ritesh Gautam, Sudhanshu Pandey, Mark Omara, Joannes D. Maasakkers , Pankaj Sadavarte, David Lyon, Hannah Nesser, Melissa P. Sulprizio, Daniel J. Varon, Ruixiong Zhang, Sander Houweling, Daniel ZavalaAraiza , Ramon A. Alvarez, Alba Lorente, Steven P. Hamburg, Ilse Aben, Daniel J. Jacob 2020 Quantifying methane emissions from the largest oil producing basin in the U.S. from 5 space 6 • Methane Emissions from the Permian Basin. Science Advances.39:  https://legacy-assets.eenews.net/open_files/assets/2020/04/23/document_ew_03.pdf

Alan Journet, Cofacilitator of Southern Oregon Climate Action Now

Many climate activists have been watching the efforts of Julia Olson and Our Children’s Trust (OCT) for many years as they assist our youth in holding governments accountable for failure to act to protect the nation’s natural resources, managed in trust for future generations.

I start with the conclusion:  this is one of the most powerful and persuasive video efforts I have seen to make the case that our institutions are failing us and that we urgently need action to address the climate crisis.

This video offers an entertaining and informative compilation of video depicting the reasons the young people initially engaged in the action combined with coverage of the ups and downs of the last few years of the campaign ending with a Court deciding that the courts have no authority or ability to establish and monitor a program that would address the climate crisis.  Tellingly, we learn the court fully accepted two of the three basic elements required to compel judicial action: that the plaintiffs have been damaged and will be damaged by global warming and that greenhouse gas emissions resulting from human activity are responsible. Despite that, and the courts being the last resort, by a 2:1 vote the three-panel bench declined to act.  Following this defeat, an undeterred OCT has filed a motion that would amend their complaint to focus on obtaining a declaratory judgment that the nation’s fossil fuel-based energy system is unconstitutional.

I was particularly struck by the segment that so very effectively responded to the perceived need of the plaintiffs to demonstrate that the government knew of the problem and its cause but simply failed to act. Rather than responding appropriately to the science presented to them, Administration after Administration has for decades assiduously dug its heels in to promoting fossil fuels rather than clean renewable energy.  This transparently (now, at least) was undertaken despite frequent placating words from both Republican and Democratic Presidents about how they vowed to protect our climate and environment for future generations.

While it is clear that, as Julia Olson argued, none of this would have happened had it not been for the energy and commitment f the plaintiffs, I think I also evident that none of it would have happened absent the dedication, commitment, and abilities of Julia Olson.  Julia’s ongoing energy, enthusiasm, and support for the plaintiffs was conspicuous throughout the film.  Kudos to Julia Olson!

As I reflected on the film, the current failure of legislators and state agencies in Oregon to hold the gas companies accountable for the misinformation and disinformation that they use to promote their product came to mind. The depressing realization that legislators, agencies, the culpable corporation executives themselves, and now the courts will not acknowledge and respond appropriately to the climate crisis led me to what seems the only remedy: if our institutions will not hold the perpetrators accountable, then we must do it ourselves. We know that racial justice, gender equality, and LGBTQ rights, for example, have made huge progress over the years.  We have seen how rapidly, after years of activist pressure, the change in public acceptance occurred once inroads were made into the public perception of the constitutional requirement for basic human justice.  The message, it seems to me, is that those of us who are aware of the urgency of the climate crisis must redouble our effort to develop the public / political will for action on this overarching problem.  The data on communication tell us that most Americans simply do not talk about the crisis.  It is almost inevitable, therefore, that they will not consider it an issue demanding their attention. Our task, then, is to get out there and talk to people about the problem and what we can do to turn this glacier-bound ship around.

The film is available through Netflix.

Alan R.P. Journet Ph.D.
Cofacilitator,
Southern Oregon Climate Action Now
7113 Griffin Lane
Jacksonville OR 97530-9342
alan@socan.eco
541-301-4107
February 21^st  2022

Chair Smith Warner and members of the House Committee on Rules:

I testify as co-facilitator of Southern Oregon Climate Action Now on behalf of the over 1600 rural Southern Oregonians who are SOCAN. Our mission is to promote awareness and understanding of the science of global warming and its climate change consequences and motivate individual and collective action to address the resulting climate crisis. We do this within the critical framework of promoting social justice.

North Dakota is the only state with a SB. Founded in 1919, the Bank of North Dakota’s mission is to “promote agriculture, commerce, and industry” and “be helpful to and assist in the development of… financial institutions… within the State.”  But several other states have considered the possibility of developing their own such system.  Most of the NDSB’s lending is done in partnership with local banks and credit unions. Student loans are the only part of the bank’s lending in which it works directly with borrowers. Notably, it has among the highest bank credit ratings in the country.

With the Bank of North Dakota, financing is made available to support loans to students, farmers and others, while the bank’s profits go into the state budget to help provide more revenue for government programs.

An important concern for us is that the major banks serve the goal of making a profit while state banks can serve the interests of the people of the state.  One of the main obstacles in our effort to combat climate change is the fossil fuel corporations continue to promote misinformation both about their product and their pretended commitment to adjusting their business model to more sustainable products. A substantial problem in this arena is that our major banks continue to support these corporations with investments and loans, thus – like those corporations – working consistently to make money at the expense of the livability of our planet.

In addition, a State Bank can focus its attention on promoting social justice rather than merely promoting profits for the managers and shareholders.

For these reasons we strongly support HJR205 and urge its passage with a ‘Do Pass’ recommendation.

It’s important to note that HJR205 doesn’t create a state bank; it merely allows the democratic process to unfold by asking the voters f they wish to adjust the rules to allows Oregon to consider such a step.

Respectfully submitted

Alan Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now

Alan R.P. Journet Ph.D.
Cofacilitator,
Southern Oregon Climate Action Now
7113 Griffin Lane
Jacksonville OR 97530-9342
alan@socan.eco
541-301-4107
February 15^th 2022

Co-Chairs Beyer and McLain and members of the Joint Committee on Transportation:

I write as co-facilitator of Southern Oregon Climate Action Now on behalf of the over 1600 rural Southern Oregonians who are SOCAN. Our mission is to promote awareness and understanding of the science of global warming and its climate change consequences and motivate individual and collective action to address the resulting climate crisis.

Transportation is the sector of our economy responsible for the largest share of regulated greenhouse gas emissions.  While this is mainly a function of the combustion of fossil fuel by vehicles, there is also a contribution from the materials employed in building our roads and bridges.  We know, for example, that cement is an extremely greenhouse gas intensive product as conventionally produced.  However, we also know there are ways to produce cement that could reduce this output.

For this reason, SOCAN endorses the concept of a pilot program to explore the potential for reducing emissions from materials production embodied in HB4139. The likelihood is that should such be found, the process could also become more efficient and less costly.

Respectfully submitted

Alan Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now

Alan R.P. Journet Ph.D.
Cofacilitator,
Southern Oregon Climate Action Now
7113 Griffin Lane
Jacksonville OR 97530-9342
alan@socan.eco
541-301-4107
February 9^th 2022

Chair Wagner and Members of the Senate Committee on Rules

I write as co-facilitator of Southern Oregon Climate Action Now on behalf of the over 1600 rural Southern Oregonians who are SOCAN. Our mission is to promote awareness and understanding of the science of global warming and its climate change consequences and motivate individual and collective action to address the resulting climate crisis.

While campaign finance reform may seem far out of the sphere of interest of a climate activist organization, it is not! Indeed, for many activists in the climate arena, campaign financing is almost the underlying cause for the abject failure of legislatures across the nation, and the world, to act appropriately on the climate crisis. Although this crisis is evident to anyone who is conscious and has their eyes open, time and again legislative action is thwarted by those who have been elected as a result of campaign contributions from the very industries exhibiting business models that are causing the problem.  We are well aware that the corridors of legislatures teem with lobbyists from the fossil fuel industry. Meanwhile, candidates for office with a hint of sympathy for fossil fuel corporation are rewarded with huge campaign contribution support virtually ensuring their election. The problem is multiplied many-fold when a state has no limits on campaign contributions.  In such a situation, the fossil fuel sources of funding can provide almost unlimited funding to encourage legislator resistance to climate action that encourages a shift away from their product.

Many of us in the climate activist arena place campaign finance reform almost as a parallel priority.  Unless we manage to reduce the impact of the egregious financial impact on our electoral process and democracy overall, we will find addressing serious environmental and social issues such as the climate crisis, difficult to impossible.  The problem, of course, is that those profiting from the abuse of our water and air are the very entities contributing financially to prevent legislation from passing that would reduce their capacity to externalize costs and require internalizing their behavior and costs.

A civilized society functions because, through our elected officials, we mutually agree on a set of rules that harness the irresponsible behavior that some members of society would display absent those rules. The problem with unlimited campaign financing is that the very individuals and entities that seek to undermine our democracy and our civilized society in order to reap profits will support candidates who support their views.

Because our civilized society is under so much threat from those willing to throw money at the campaigns of candidates who will represent their anti-social attitudes and thwart sane legislative proposals, Southern Oregon Climate Action Now supports the efforts embodied in SB1526 and SB1561 to regulate campaign financing in Oregon.  Since the state is one of very few states that still allows unlimited financing of campaigns, passage of a measure to restrict this opportunity would enhance the reputation of the state substantially.  Although there those claiming ‘money is free speech’ as decided by the U.S. Supreme Court in Citizens United v. Federal Election Commission, 558 U.S. 310 (2010), we reject that assertion as patently absurd. Establishing campaign finance rules in the state of Oregon would not only enhance democracy in the state and our ability to address critical environmental and social issues, it would also enhance our reputation in this arena throughout the nation.

We therefore urge the sponsors of SB1526 and SB1561, along with the Senate Committee on Rules to develop a composite bill that serves the purpose of each and comprises the best elements of both proposals.

Respectfully submitted

Alan Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now