Commissioner Cheryl A. LaFleur Statement
May 30, 2018
Docket No. CP17-463-000
Concurrence on Florida Southeast Connection, LLC (Okeechobee Lateral)
“Today’s order grants a certificate authorization for the Okeechobee Lateral Project. 1
This lateral pipeline will provide up to 400,000 dekatherms per day (Dth/day) of firm transportation service from the Florida Southeast mainline to the Okeechobee Clean Energy Center. 2
I believe the project is in the public interest after carefully balancing the need for the project and its environmental impacts.
“I am concurring today to note my continued disagreement regarding the Commission’s determination that it is unable to discern the significance of downstream greenhouse gas (GHG) emissions. Those concerns are expressed fully in my dissent in Sabal Trail. 3
As in Sabal Trail, the Commission has quantified and disclosed the downstream GHG emissions of this project, but fails to determine the significance of those GHG emission estimates. I reject the contention that the Commission cannot ascribe significance to a given rate or volume of GHG emissions. We are required by the National Environmental Policy Act (NEPA) to reach a determination regarding the significance of all environmental impacts, including the indirect impacts of downstream GHG emissions. It is our responsibility to use the best information we have, on a case-by-case basis, to make that determination.
“As I discussed in Sabal Trail, the Social Cost Carbon is a scientifically-derived metric to translate tonnage of carbon dioxide or other GHGs to the cost of long-term climate harm. The Social Cost of Carbon has been used as a means to monetize the cost impacts of GHG emissions as part of an overall cost-benefit evaluation of a proposed action or rulemaking. I believe it would more readily apply to a proposed pipeline project if we developed a fuller record to support a quantified cost-benefit approach to our pipeline reviews.
“In this case, I have considered the GHG emissions for the Okeechobee Lateral Project by comparing the emissions estimates to the total state and national emission inventories and calculating how this project increases those GHG inventories. I do not think we should shirk our responsibilities under the Natural Gas Act and NEPA by refusing to determine the significance of GHG emissions simply because consideration of climate change in our pipeline review is difficult.
“For all of these reasons, I concur.”