FERC Limits Consideration of GHGs

On May 18, 2018, the Federal Energy Regulatory Commission (FERC) clarified that it will not consider upstream and downstream greenhouse gas emissions when conducting environmental reviews of natural gas pipelines. FERC reasoned that upstream emissions associated with natural gas production and downstream emissions association with natural gas combustion are too attenuated and uncertain to warrant consideration. FERC announced the policy in an order denying rehearing of its decision to certify the Dominion Pipeline. FERC will continue to continue to analyze upstream and downstream effects when they are “sufficiently causally connected to and are reasonably foreseeable effects of the proposed action.”