Comments on Certification of New Interstate Natural Gas Pipeline Facilities
July 2018
The Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) concerning possible changes to its Policy Statement on the certification of new natural gas pipeline facilities. Analysis Group Senior Advisor Susan Tierney, an expert in energy policy and the natural gas industry, took the opportunity to submit comments to FERC on the topic. In an earlier white paper, Dr. Tierney had drawn attention to the “many changes [that had] occurred in the gas industry in the two decades since the Commission issued its Policy Statement in 1999.” In her comments on FERC's NOI, she applauded what she called the commission's “timely and important decision to take a fresh look at how the agency reviews proposals to certificate new interstate natural gas facilities.”
Dr. Tierney recommended that FERC revise its Policy Statement and “administer it loyally so as to support decisions in the public interest.” Her substantive comments took the form of a series of specific recommendations for revision of the policy, among them:
- Make Need Determination the threshold question in its review of facility proposals
- Apply a more systematic and comprehensive Need Analysis in reviews of facility applications
- Minimize reliance on precedent agreements
- Consider both positive and negative impacts of the use of natural gas