Greenhouse Gas Mitigation: Natural Gas Act Sections 3 and 7 Authorizations

Welcome and Opening Remarks

Panel 1:  The Level of Mitigation for a Proposed Project’s Reasonably Foreseeable Greenhouse Gas Emissions

This panel will explore how the Commission could determine the quantity of reasonably foreseeable greenhouse (GHG) emissions, resulting from a project proposed under section 3 or 7 of the Natural Gas Act and the appropriate level of mitigation for such emissions.  The panel may include a discussion of the following questions:

1. When determining the amount of reasonably foreseeable GHG emissions associated with a proposed project, how could the Commission consider:  project utilization projections; State or regional natural gas usage projections from Public Utility Commissions or other entities; individual emissions data for industrial or electric generation customers; known netting effects from displacement of higher or lower emitting sources, including displacement that may occur over the life of the project; or other factors? 
2. What is the appropriate level of mitigation associated with GHG emissions for a proposed project?  Should the Commission determine the amount of mitigation required on a case-by-case basis or should the mitigation levels be set at zero, less than significant, or some other level?  

Panelists:

• Dr. Susan Tierney, Senior Advisor, Analysis Group, Inc. | Presentation
• Scott Hallam, Senior Vice President, Transmission and Gulf of Mexico, Williams | Presentation
• Moneen Nasmith, Senior Attorney, Earthjustice
• Hon. Joseph T. Kelliher, Principal, Three Acorns
• Jennifer Danis, Senior Fellow, Sabin Center | Presentation
• Pat Outtrim, President, Outscan Resources
• Melissa Hoffer, Principal Deputy General Counsel, Environmental Protection Agency

Break

Panel 2:  Types of Mitigation

This panel will focus on types of mitigation measures a project sponsor could employ to reduce the amount of GHG emissions associated with their proposed project.  The panel will discuss measures including physical (i.e. non-market-based) mitigation measures, such as the use of technology-based mitigation measures to reduce fugitive methane emissions at project facilities, installation of renewable energy sources to offset gas or electricity usage at project facilities, use of combined cycle or combined heat/power systems on turbine compressor units, carbon capture and storage (e.g., sequestration), or environmentally based measures, such as planting trees to offset carbon emissions or restoring wetlands to provide additional carbon storage.  Additionally, the panelists will explore the effectiveness and availability of market-based mitigation such as carbon offset purchases, renewable energy credits, and emissions allowances to offset GHG emissions.  The panelists will discuss current mitigation measures employed by project sponsors at their facilities or by end-users and future technologies.  The panel may include a discussion of the following questions:

1. What types of physical mitigation associated with GHG emissions are project sponsors currently using at their facilities? What types of physical mitigation associated with GHG emissions project sponsors are currently available to project sponsors?  Are there limitations to physical mitigation measures?
2. What types of market-based mitigation associated with GHG emissions are project sponsors currently using? What types of alternative or market-based mitigation associated with GHG emissions project sponsors are currently available to project sponsors?
3. Are market-based mitigation measures effective and verifiable methods of mitigation over the life of a project?  What effects would this type of mitigation from Commission-jurisdictional projects have on offset, REC, and GHG compliance markets? 
4. Should project applicants submit mitigation proposals with their project application?  How soon might current project applicants be able to supplement the record or respond to a Commission data request with their mitigation proposal? 
5. What factors should the Commission consider in evaluating the sufficiency of a mitigation proposal?

Panelists:

• Ivan Van der Walt, Chief Operating Officer, NextDecade Corporation | Presentation
• Dr. Anna Scott, Chief Science Officer, Project Canary | Presentation
• Caitlin Tessin, Director, Market Innovation, Enbridge | Presentation
• Gary Choquette, Executive Director of Research and IT, Pipeline Research Council International | Presentation
• Suzanne Walzter, Deputy Branch Chief, Environmental Protection Agency
• Bill Donahue, Manager, Natural Gas Resources, Puget Sound Energy | Presentation
• Dr. Nicky Sheats, Director, Center for Urban Environment, John S. Watson Institute for Public Policy

Panel 3:  Compliance and Cost Recovery of Mitigation

At present, the Commission’s post-certificate environmental monitoring  commences at project construction and ends once Commission staff deems additional restoration inspections are not necessary.  This panel will explore methods for the continued verification and accounting of GHG mitigation during project operation.  This panel also will discuss the cost impacts to the industry from implementing GHG mitigation measures and how project sponsors might recover those costs.  The panel may include a discussion of the following questions:

1. How could the Commission ensure continued verification and accounting of GHG mitigation measures since the Commission would need to monitor and assess mitigation during the life of the project?
2. Are there federal or state agencies which currently monitor compliance of GHG mitigation measures?  Should the Commission explore potential interagency agreements or memorandums of understanding with other federal agencies to monitor compliance of GHG mitigation measures?
3. How could the Commission allow project sponsors to recover the costs of market-based mitigation measures, such as the purchase of offsets?  Would allowing recovery of such costs through an annual tracker or surcharge be appropriate? 

Panelists:

• Stephen Mayfield, AGM-Gas Operations, City of Tallahassee | Presentation
• Chris Humes, Senior Vice President of Operations and Projects, TC Energy
• Dr. Carl Pechman, Director, National Regulatory Research Institute
• Hon. Diane X. Burman, Commissioner, New York State Public Service Commission
• Paula VanLaningham, Global Head of Carbon, S&P Global Platts
• Rachel Dawn Davis, Public Policy and Justice Organizer, Waterspirit | Presentation

Closing Remarks