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Commissioner Richard Glick Statement
May 17, 2018
Docket No. CP17-476-000

Item No. C-1 PDF
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Gulf South Pipeline Company, LP

“Today, the Commission determines that the Westlake Expansion Project, which will enable Gulf South to provide the new Lake Charles Power Plant with incremental natural gas transportation service, is required by the public convenience and necessity.1 I dissent in part from today’s order because I do not believe the Commission can find that the Project is in the public interest without determining the significance of the Project’s contribution to climate change.

“Given the Project’s capacity is designated for the Lake Charles Power Plant, the Environmental Assessment (EA) finds that “[t]he Project would result in direct and downstream GHG emissions and would contribute to global increases in GHG levels.”2 However, the EA summarily concludes that the Commission “cannot make a finding” whether the Project’s GHG emissions would significantly contribute to climate change. The Commission nevertheless proceeds to find that the Project will have no significant impact on the environment.4

“While quantifying and disclosing downstream GHG emission tonnage is a necessary step to value the environmental impacts of climate change, it does not actually assess the impact or harm from climate change.3 As I stated in my Sabal Trail dissent,5 I do not agree that “no standard methodology exists to determine how a project’s contribution to GHG emissions would translate into physical effects on the environment for purposes of evaluating the Project’s impact on climate change.”6 The Social Cost of Carbon, which translates the long-term damage done by a ton of carbon dioxide into monetary value, provides a meaningful approach to convert GHG emissions into a qualitative figure demonstrating impact.

“Accordingly, I respectfully dissent in part.”


    1 Gulf South Pipeline Company, LP, 163 FERC ¶ 61,124 (2018).
    2 Environmental Assessment at 51.
    3 Id. at 52.
    4 Gulf South, 163 FERC ¶ 61,124 at P 33.
    5 Fla. Se. Connection, LLC, 162 FERC ¶ 61,233, at 2, 5–8 (2018) (Glick, Comm’r, dissenting).
    6 Environmental Assessment at 52.
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