Comment of Sierra Club under PF15-4.
04/02/2015UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION IN THE MATTER OF ) ) Gulf South Pipeline Company, LP ) Docket No. PF15-4 ) ) Sierra Clubs Scoping Comment and Filing of DOEs LNG Environmental Review Materials and Comments of Sierra Club, et al., Thereon Sierra Club submits the following in response to request to the Commissions request for comments on the scope of the environmental analysis in the above-captioned docket. Because the purpose of this pipeline, as stated by the applicant, is explicitly to enable delivery of natural gas to the Freeport LNG export project, liquefied natural gas exports, and the production of additional gas for export, is an indirect effect of this project that must be considered in the commissions environmental review. To facilitate that review, Sierra Club is attaching copies of the Department of Energys (DOE) Addendum to Environmental Review Documents Concerning Exports of Natural Gas from The United States and associated reports authored by the National Energy Technology Laboratory (NETL), together with comments submitted by Sierra Club, et al., on these studies. The DOE and NETL studies address many of the impacts of natural gas production and the lifecycle impacts of liquefied natural gas exports. Although Sierra Club contends that these studies present only a partial picture, as explained in the comments Sierra Club submitted thereon and attaches here, these studies provide an important starting point for FERCs analysis. To ease review of these materials, Sierra Club is submitting them in two separate FERC filings, corresponding with the two separate comments Sierra Club filed regarding these materials. The first filing contains: DOEs Addendum to Environmental Review Documents Concerning Exports of Natural Gas from The United States NETLs Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States Sierra Clubs Comment on Gas Production and exhibits thereto. The second contains: NETLs Life Cycle Analysis of Natural Gas Extraction and Power Generation NETLs Environmental Impacts of Unconventional Natural Gas Development and Production Sierra Clubs Comment on Climate Impacts of LNG Exports and exhibits thereto. Sincerely, Nathan Matthews Staff Attorney Sierra Club 85 2nd St., Second Floor San Francisco, CA 94105 nathan.matthews@sierraclub.org