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Commissioner Cheryl A. LaFleur
July 19, 2018
Docket Nos.
CP17-441-000, CP17-441-001
Item No. C-3

Order: C-3 PDF
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Concurrence on Northwest Pipeline’s North Seattle Project

“Today’s order grants Northwest Pipeline’s request for authorization to construct and operate the North Seattle Lateral Upgrade Project (North Seattle Project). I believe the project is in the public interest after carefully balancing the need for the project and its environmental impacts. For the reasons discussed below, I concur.

“In this case, the Commission quantified and disclosed the upper-bound estimate of the downstream greenhouse gas (GHG) emissions associated with the North Seattle Project.1 The volume of GHG emissions associated with the downstream use would result in about 4.1 percent increase in GHG emissions in Washington2 and a 0.05 percent increase of national GHG emissions.3 Going forward, at a minimum, I believe we should continue to do this GHG quantification and analysis as part of our environmental review of pipeline projects. I recognize that this full-burn estimate is simply a mathematical derivative of pipeline volume, but I believe we should disclose it and consider it as part of my public interest determination, particularly where there is not more precise evidence of downstream pipeline utilization. In the future, more information in the record regarding the identified end uses would enable the Commission to more accurately assess indirect impacts of downstream GHG emissions by calculating gross and net GHG emissions as part of our National Environmental Policy Act (NEPA) responsibilities.

“As for the upstream impacts associated with the North Seattle Project, the order does not respond to intervenors concerns to include even the generic upstream information we have been disclosing since 2016.4 I do not support this decision. While it is less clear that upstream effects are caused by the pipeline, I would respond to upstream GHG comments by disclosing the best available information, such as the DOE studies cited in past orders. However, today’s order rejects that approach, and applies the Commission’s new policy that limits the review and disclosure of upstream and downstream GHG impacts as part of our NEPA responsibilities and public interest determination under the Natural Gas Act (NGA).5 I note my continuing strong disagreement with this change in policy.

“For all of these reasons, I concur.”


    1 The EA includes an estimate of the upper-bound downstream GHG emissions based on the project transporting up to 196,311 dekatherms per day (Dth/d). However, Northwest revised its application reducing the incremental capacity of natural gas delivered by Northwest’s system to 159,299 Dth/d. Using the projects revised capacity, if all 159,299 Dth/d of natural gas were transported to combustion end uses, downstream end use would result in the emissions of about 3.1 million metric tpy of CO2e.
    3 U.S. Environmental Protection Agency, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2016, April 12 2018.
    One way the Commission could assess the significance of a given rate or volume of GHG emissions is to compare the downstream GHG emissions associated with an individual project to the total state, regional, and/or national emission inventories.
    4 The Commission has relied on recent DOE studies to provide generic estimates of impacts associated with upstream natural gas production, including production related GHG emissions. Commission orders that contained this generic upstream information acknowledged the limitations of providing such data because we did not have more detailed information such as the number, location, and timing of the wells, roads, and gathering lines as well as details about production methods. Dep’t of Energy and Nat’l Energy Tech. Laboratory, Life Cycle Analysis of Natural Gas Extraction and Power Generation, DOE/NETL-2015/1714 (Aug. 30, 2016) (2016 DOE/NETL Study); U.S. Energy Info. Admin., The Growth of U.S. Natural Gas: An Uncertain Outlook for U.S. and World Supply (June 15, 2015),; Dep’t of Energy and Nat'l Energy Tech. Laboratory, Environmental Impacts of Unconventional Natural Gas Development and Production, DOE/NETL-2014/1651, (May 29, 2014) (2014 DOE/NETL Study).
    5 See Dominion Transmission Inc., 163 FERC ¶ 61,128 (2018) (LaFleur, Comm’r, dissenting in part) (New Market).
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