Underground Construction - October 2021 - 11

plained that " construction and operation of
the project would increase the atmospheric
concentration of [greenhouse gases] in
combination with past, current and future
emissions from all other sources globally
and contribute incrementally to future
climate change impacts, " according to the
court decision.
What the Commission did not do was
determine the " signifi cance " of the GHG
emissions' contribution to climate change,
which the NEPA arguably requires the
agency to do. Th e Commission claimed
there was no methodology that allows it to
calculate the GHG impact on a regional or
even national level.
Th e Sierra Club led a group of local
Texas environmental and citizen groups in
fi rst contesting FERC's project approvals
and then at the DC Appeals court. Th ey
objected to FERC's EIS because it did not
use the " social cost of carbon " protocol or
some other generally accepted methodology
to evaluate the impact of each project's
contribution to climate change.
Th e current Social Cost of Carbon is approximately
$50 per ton. James Auslander,
an attorney at Beveridge & Diamond, said
in a blog post, that number is expected
to increase signifi cantly when the Biden
Administration completes its review and
updates the Social Cost of Carbon analysis
over the next few months.
" Th is latest decision may also bolster
soon-expected federal recommendations
for agencies to expand use of the Social Cost
of Carbon beyond rulemaking actions to
also encompass individual project reviews,
and new federal guidance on consideration
of GHGs in NEPA analysis, " he wrote.
" Because of the substantial costs associated
with GHG emissions, use of the Social
Cost of Carbon is likely to weigh heavily
against pipelines in FERC's public interest
analysis under the Natural Gas Act, at least
if the pipeline fails to demonstrate that the
gas it proposes to transport would reduce
overall GHG emissions by, for example,
displacing GHG-intensive electric generation
or providing low-GHG alternatives to
transportation fuels. "
To assess the environmental justice
impacts of each project, the Commission
examined the impacts on communities in
census block groups within a two-mile radius
of the project site, but not on communities
farther afi eld. Th e Commission found
that all communities within those census
blocks were minority or low-income. Th e
Commission examined potential ecological,
aesthetic, historical, cultural, economic,
social or health impacts within those
communities. Th e Appeals Court stated
FERC should have gone beyond those
census tracks when checking on minority
communities. *
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Underground Construction - October 2021

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