Commissioner Cheryl A. LaFleur and Commissioner Richard Glick
October 17, 2018
Docket No. CP16-121-000
We concur in the Commission’s decision to grant National Grid LNG LLC authorization to add liquefaction facilities at its existing Fields Points liquefied natural gas storage facility under section 7 of the Natural Gas Act.1
We write separately to highlight the need to evaluate the significance of all environmental effects under the National Environmental Policy Act, including greenhouses gas (GHG) emissions. We agree with today’s finding that the liquefaction facility will not have a significant effect on the environment,2
particularly given the limited GHG emissions associated with the project.3
However, we disagree with the language in the Environmental Assessment that dismisses the Social Cost of Carbon as a useful tool to inform the environmental review, stating the Social Cost of Carbon method “cannot meaningfully inform the Commission’s decision whether and how to authorize a proposed project under the NGA.”4
We believe the Social Cost of Carbon provides a meaningful and informative approach for an agency to consider how its actions contribute to the harm caused by climate change.5
By translating the long-term damage done by a ton of carbon dioxide into monetary value, the Social Cost of Carbon offers a method for linking GHG emissions to particular climate impacts, helping satisfy our obligation to consider how the Commission’s actions contribute to the harm caused by climate change.
For these reasons, we respectfully concur.