Docket No. CP21-94-001
I concur in today’s order. As noted in today’s order, the record does not identify any upstream greenhouse gas (GHG) emissions that are a reasonably foreseeable result of or causally connected to the Regional Energy Access Expansion (REAE) pipeline. Whatever our authority under the Natural Gas Act (NGA), I do not believe that there would be any upstream GHG emissions to factor into our analysis. Simply put, I do not see a need, in this proceeding, to spill ink on what authority we do—or do not—have to consider upstream GHG emissions under section 7 of the NGA where the record does not identify any upstream GHG emissions associated with the project.
I am committed to ensuring that the Commission does not stand in the way of critical energy infrastructure that is needed for reliability and in the public interest. The issuance of today’s action clears the way for REAE to receive a notice to proceed with the necessary pre-construction work on the project right-of-way, including work that needs to be completed by March 31, when the critical construction windows end to protect certain threatened and endangered species.
The reality is that failing to issue a timely order in this proceeding would almost certainly delay the development of REAE for at least year, meaning that it would not be available for the upcoming winter heating season. Such a failure would also jeopardize reliability and the economic benefits, including jobs, associated with the REAE pipeline, which was unanimously approved by the Commission in the underlying order.
For the above reasons, I respectfully concur.