In comments submitted to DEC on proposed amendments by the NYS Department of Environmental Conservation (DEC) to the State Environmental Quality Review (SEQR) process, CLP recommends that DEC more comprehensively address the greenhouse gas (GHG) emissions of proposed fossil fuel infrastructure projects by taking into account all upstream and downstream emissions of those projects. To illustrate the importance of reviewing these emissions, and demonstrate a process for doing so, CLP has prepared a worked example estimating the indirect emissions from the proposed Pilgrim pipelines and comparing them to New York State’s energy and climate goals.
The quantity of emissions at stake is significant. We estimate that the total emissions from producing, processing, and combusting the oil that would be carried by the pipelines are 32-43 million metric tons (MMT) per year. This is greater than the current emissions from all electricity generation in the state, and it’s enough to offset all of the climate gains New York has pledged to achieve from all state policies over the next 13 years. It’s also almost as large as New York's total in-state emissions will be when it achieves its 2050 emissions goals. Because these pipelines could last 50 years or more, they could lock in an essential doubling of New York's climate footprint for years to come.
Although much of these emissions would take place outside of New York State, CLP believes it is important for New York's climate leadership that all emissions associated with infrastructure built in the state be considered when evaluating projects’ environmental impacts.