Here Today, Gone Tomorrow? FERC’s Natural Gas Pipeline Greenhouse Gas Analysis Policy
The Republican majority of the Federal Energy Regulatory Commission (“FERC” or “Commission”) has drawn a clear distinction with how and when the Commission will analyze upstream and downstream greenhouse gas (“GHG”) emissions when reviewing natural gas pipeline projects. But with the resignation of Republican Commissioner Robert Powelson, a pending Notice of Inquiry issued by the Commission, a separate advanced Notice of Proposed Rulemaking issued by the Council on Environmental Quality (“CEQ”), and a recent petition to the U.S. Court of Appeals for the D.C. Circuit, this current established protocol may not last and by this time next year we may see a whole new approach to pipeline GHG analysis coming out of FERC.
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“Here Today, Gone Tomorrow? FERC’s Natural Gas Pipeline Greenhouse Gas Analysis Policy,” by Stephen C. Zumbrun was published in the November–December 2018 edition of Pratt’s Energy Law Report (Vol. 18, No. 10), an A.S. Pratt Publication, LexisNexis. Reprinted with permission.
This article was first published on July 19, 2018, as a Blank Rome Energy and Environmental Trends Watch blog post.