Regulatory Submissions

On January 7, APGA submitted comments asking the Federal Energy Regulatory Commission (FERC) to fully appreciate cost impacts for any greenhouse gas (GHG) mitigation measures it may require moving forward. The comments were in response to a technical conference FERC held late last year, which explored methods natural gas companies may use to mitigate the effects of direct and indirect GHG emissions resulting from its authorizations.

APGA member Stephen Mayfield from City of Tallahassee participated in FERC’s technical conference this past November, where participants discussed whether FERC had the authority to require GHG mitigation efforts, to what extent mitigation might be required, what type of mitigation might be permitted, and how those costs might be recovered by project sponsors. Echoing many of the statements Stephen made during the technical conference, APGA’s comments asked FERC to avoid duplication of regulatory activities and to always consider cost impacts to the end consumer.

APGA’s comments also requested that FERC clearly determine whether it has the jurisdiction to require GHG mitigation efforts, including whether those efforts are necessary and appropriate, before proceeding with any additional requirements.