C-8: Commissioner Christie’s Concurrence on Transco Southside Reliability Project Order

Docket No. CP22-461-000

I concur with the finding in PP 54-58 that the upstream GHG emissions are not reasonably foreseeable.   

Beyond that finding, which is sufficient to concur with this Order, I would add that the Commission has no legal obligation to estimate or consider emissions from upstream, non-jurisdictional activities.  Further, the Commission has no legal authority whatsoever to order mitigation of such non-jurisdictional upstream activities, much less to consider such non-jurisdictional upstream emissions in our merits review under the Natural Gas Act.

For these reasons, I respectfully concur.