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Commissioner Richard Glick
October 1, 2018
Docket Nos.
CP18-37-000, CP18-38-000
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Concurring Statement in Sierrita Gas Pipeline LLC

We concur in the Commission’s decision to grant Sierrita Gas Pipeline LLC’s (Sierrita) authorization for the Compressor Expansion Project (Project) to increase the export capacity of its cross-border facility into Mexico under the Natural Gas Act (NGA) section 31 and add a new compressor station under NGA section 7.2 We write separately to highlight the need to evaluate significance of all environmental effects under the National Environmental Policy Act, including greenhouses gas (GHG) emissions. We agree with the today’s finding that the Project will not have a significant effect on the environment,3 particularly given the limited GHG emissions associated with the expansion.4 Yet, in reaching this conclusion, the EA states that it “cannot determine whether the Project’s contribution to climate change would be significant” due to “no generally accepted significance criteria for GHG emissions.”5 To the contrary, the Commission has the tools to “determine the Project’s incremental physical impacts on the environment caused by GHG emissions.”6 This is precisely what the Social Cost of Carbon provides. It translates the long-term damage done by a ton of carbon dioxide into a monetary value, thereby providing a meaningful and informative approach for an agency to consider how its actions contribute to the harm caused by climate change.

For these reasons, we respectfully concur.


    1 15 U.S.C. § 717b (2012).
    2 15 U.S.C. § 717f (2012).
    3 Sierrita Gas Pipeline LLC, 165 FERC ¶ 61,001 at P 36 (2018); Environmental Assessment (EA) at 81.
    4 EA at 56.
    5 Id. at 74.
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