By Tom Russo
Russo on Energy LLC (RoE) filed comments on FERC's Notice of Inquiry on whether, and if so how, it should revised its current policy on whether interstate gas facilities are in the public interest. RoE's views were based on its independent research and did not represent any of the current stakeholders in Docket No. PL18-1-000. RoE comments can be summarized as follows:
- FERC should not second guess the markets nor abandon precedent agreements entirely as a determination of need. Instead, the Commission should supplement its needs analysis with official comments from state energy agencies and public utility commissions, especially when affiliate companies are involved;
- FERC should use it new Office of Public Participation and existing Dispute Resolution Service to facilitate settlements among gas facility applicants and landowner, EJ communities and other stakeholders including state agencies;
- FERC should condition certificates to implement technologically feasible mitigation measures to reduce intended and unintended methane and CO2 emissions or require the development of such plans during the life of the project;
- FERC should increase oversight and enforcement of conditions to mitigate environmental impacts during construction and ensure restoration of land;
- FERC should require on the ground surveys to identify environmental justice communities and not rely solely on census data;
- FERC should use the 4 As of energy security (availability, accessibility, affordability and acceptability) as a framework to determine whether or not a project is in the public interest;
- FERC should revise it Pipeline Policy to communicate to interstate natural gas pipeline applicants that it values mitigation measures that reduce intended and unintended methane and CO2 emissions on proposed facilities; and
- FERC's revised policy statement should also communicate the natural gas and oil industry how it values decarbonization efforts being developed using Responsibly Sourced Gas, Renewable Natural Gas and Blending of Hydrogen in natural gas pipelines.
Download the official comments here.