Comments of Virginia Chapter of the Sierra Club under CP16-10, et. al.

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION In the Matter of MOUNTAIN VALLEY PIPELINE, LLC Docket Nos. CP16-10-000 EQUITRANS, LP CP16-13-000 COMMENTS OF THE VIRGINIA CHAPTER OF THE SIERRA CLUB ON GREENHOUSE GAS EMISSIONS AND CULTURAL ATTACHMENT Appalachian Mountain Advocates hereby files the following comments on behalf of the Virginia Chapter of the Sierra Club. The following comments and supporting documents address the greenhouse gas emissions associated with four interstate natural gas transmission lines proposed to be built in Virginia and request that FERC perform a cultural attachment review as part of the NEPA process for all such pipelines in Virginia. Respectfully submitted, Benjamin A. Luckett Appalachian Mountain Advocates PO Box 507 Lewisburg, WV 24901 (304) 645-0125 bluckett@appalmad.org Joseph M. Lovett Appalachian Mountain Advocates PO Box 507 Lewisburg, WV 24901 (304) 645-9006 jlovett@appalmad.org GHG Emissions Associated with Two Proposed Natural Gas Transmission Lines in Virginiai Summary of GHG Emission Estimates The primary purpose of this white paper is to estimate possible greenhouse gas (GHG) emissions associated with several proposed new interstate natural gas transmission lines that would run through parts of Virginia. By associated emissions we mean the major GHG emissions that are estimated to occur (a) from operation of the transmission pipelines, (b) from the upstream stages of production and processing of the natural gas that is intended to go into to those transmission pipelines, and (c) from combustion of the transported natural gas. (The analysis excludes leaks from local distribution lines, which we assume would be avoided if the gas will be combusted in large plants connected closely to the transmission lines; however, local distribution lines are a major source of methane emissions and would need to be accounted forin addition to combustion emissionsif deliveries are first made to local gas distributors.) The four major interstate natural gas transmission lines and their daily throughputs of gas proposed in Virginia are the Atlantic Coast (ACP, 1.5 bcf/day), the Mountain Valley (MVP, 2.0 bcf/day), the WB Xpress Project to expand the capacity of the Columbia Gas Transmission pipeline by 1.3 bcf/day), and the Appalachian Connector (up to 2 bcf/day), for a total of 6.8 bcf/day. Our emission estimates for the Atlantic Coast (ACP) and Mountain Valley (MVP) pipelines are summarized in Figures 1 and 2, respectively. The base case (in the first column of the Figures) is from a published analysis: that of Laurenzi and Jersey (2013), referred to here ...