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.
Southern Oregon Climate Action Now
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.”
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.
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