Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
Re: Virginia Reliability Project, Columbia Gas Transmission, LLC Docket No. PF22-3-000 and Commonwealth Energy Connector Project, Transcontinental Gas Pipe Line Company, LLC, Docket No. PF22-4-000
Dear Secretary Bose:
On behalf of the Chesapeake Climate Action Network (CCAN) and our undersigned members, thank you for the opportunity to comment on the scope of environmental issues that the Federal Energy Regulatory Commission (FERC) should consider when evaluating the Virginia Reliability Project and the Commonwealth Energy Connector Project.
We would like to express our overall opposition to the proposed Virginia Reliability Project and the Commonwealth Energy Connector. At a time when scientists are calling climate change a “code red for humanity,” we do not support expanding fossil fuel infrastructure. In addition, we have specific recommendations to ensure that FERC considers the proper scope of issues in its environmental review of the connected pipelines.
First, we strongly encourage FERC to fully consider the need for the project given the availability of affordable clean energy alternatives and state, regional, and national greenhouse gas reduction goals. This consideration should include a review of existing and reasonably foreseeable regional infrastructure, including renewable resources. The description of the Virginia Reliability Project contains a statement of need — the “project would meet the increasing market demand of residential, commercial, and industrial consumers in southeast Virginia.” The Commonwealth Energy Connector Project contains no such statement of need. The needs assessment is critical to FERC’s determination of whether a project is in the public interest. FERC must make its own independent determination of the need for the projects, taking a hard look at all the factors.
Given the climate crisis, FERC must consider how these proposals to expand gas infrastructure will contribute to climate change. This consideration must include an analysis of upstream and downstream greenhouse gas emissions. FERC must put these emissions into the appropriate context, comparing them to regional emissions (not nationwide emissions), analyzing how this increase will impact our ability to meet national and local greenhouse gas reduction goals, and calculating the climate damages from the proposed action by using the federal government’s social cost of carbon tool. In addition to considering how the project will contribute to climate change, FERC must also analyze how climate changes — increased flooding and more severe storms, for example — would impact the project.
We appreciate FERC’s attempt to include these types of considerations in its reviews, namely the two policy statements FERC issued last month that provide guidance regarding the certification of interstate gas pipelines and consideration of greenhouse gas (GHG) emissions in gas project reviews. While we appreciate the importance of public input, we worry that the recent change to these documents, which opened them up to public comment and changed them to non-binding drafts, are attempts to delay the implementation of these common sense changes at a time when we cannot afford any more delay.
The areas of proposed works include environmental justice communities. FERC should make sure it has an adequate understanding of the areas proposed for upgrade and development. This would not only include an assessment of energy needs in the area, as discussed above, but also include baseline water and air testing. Currently there are NO records of this sort on file with the Department of Conservation and Recreation for the Suffolk region, so much of the analysis would be new. It is important for FERC to understand the legacy pollution in some of the areas to understand the true impacts the project would have on the communities.
Given the potential impacts to environmental justice communities, the new Office of Public Participation should conduct rigorous and extensive outreach using multiple forms of communicationThis region has a number of broadband gaps, so posting online is not sufficient. This outreach should also include nearby civic leagues (including but not limited to the NAACP), local institutions such as libraries and community centers, and door-to-door outreach where necessary. There should be radio notices, as well as several recurring notices in print media.
We appreciate you opening up the public comment period and hope you take these ideas into consideration.
